Privacy Policy and Terms of Use

PRIVACY POLICY

GENERAL PROVISIONS

1. Purpose of this document

1.1. This document establishes the rules for processing users' personal data and defines the procedures for collecting, using, storing, and protecting such data. It describes how we protect your personal information, what rights you have, and how you can manage your data when using our services.

2. Which services and products this document covers

2.1. This document applies to all services and products provided by our platform, including but not limited to:

2.2. The website containing the BeFluent platform materials, including all sections, pages, and functionality: https://befluent.net/

2.3. Educational courses and subscriptions, including paid and free programs.

2.4. The BeFluent platform, the BeFluent Camp educational initiative (https://www.befluent.net/camp), and other educational initiatives hosted on the Company's resources listed above and below.

2.5. Additional services such as webinars, chats with teachers, homework review, and other tools for learning the Russian language.

2.6. The BeFluent mobile applications for iOS and Android, and third-party integrations, where applicable.

3. Who owns the platform and other educational initiatives referenced in this document

3.1. The platform is owned and operated by BeFluent Company, registered at 8834 Reseda Blvd PMB 3016, Northridge, CA 91324, USA. If you have questions regarding this document or the use of your data, you may contact us by email at [email protected].

WHAT INFORMATION WE COLLECT

4. Information you provide to us

4.1. We collect personal data that you voluntarily provide when registering on the Site, expressing interest in receiving information about us or our products and Services, participating in activities on the Site, or contacting us.

4.2. Personal data

• Email address and password — required to create an account;
• First and last name — optional; you can add or change them in your profile at any time;
• Profile photo — only if you upload one yourself;
• User preferences regarding foreign-language proficiency level.

4.3. Payment data

When you purchase a subscription and enter payment details, you provide them to the payment system Stripe. All payment data is transmitted to and stored by Stripe. We do not store or have access to your full card details. Learn more about Stripe's privacy policy at: https://stripe.com/privacy.

If you purchase a subscription through app stores such as the Apple App Store or Google Play, all payments, subscription management, and refunds are governed by the policies of those platforms. We do not process or control such transactions, and any questions regarding payments, refunds, or subscription cancellation should be directed to Apple or Google directly. To give you access, we receive from the store a record of your purchase (a purchase token, the plan and the subscription status), linked to your BeFluent account ID. There is one exception to cancellation: when you delete your BeFluent account, we cancel your Google Play subscription automatically (see section 21.2). An App Store subscription is not cancelled when you delete your account — please cancel it in your Apple ID settings.

4.4. Data from social networks

If you register on our platform through Sign in with Apple or Sign in with Google, we receive information from those services in accordance with your privacy settings. (Sign-in with Facebook is no longer offered; accounts created that way can sign in with email after setting a password via "Forgot password".) This may include:

• First and last name (if listed in your social network profile);
• The email address linked to your account.

We do not import your profile picture from these services: a profile photo appears in your account only if you upload one yourself.

4.5. Educational data

We collect information related to your learning process on the platform in order to provide a personalized experience, track progress, and help you reach your language goals. This may include:

• Learning progress — information about completed lessons, watched videos, completed assignments, and overall learning dynamics.
• Homework and tests — test results, completed exercises, uploaded files (if applicable), and teacher comments.
• Grades and certificates — test scores, completed levels, certificates earned, and other confirmations of successful learning.
• Interaction history — time spent on the platform, frequency of visits, topics covered, and courses or sections of interest.
• Communication with teachers and other participants — comments, messages, and questions within the educational process (if forums, chats, or group classes are provided).
• Vocabulary data — the words you add, your vocabulary test results and level, your vocabulary track and practice history.

This data allows us to provide personalized recommendations, improve educational content, and ensure a more comfortable learning experience.

4.6. Data from our mobile apps, notifications and support chat

• Notifications — we do not currently send push notifications. Our learning website (learn.befluent.net) asks your browser for permission to show them, after you sign in and before a purchase. The new BeFluent apps for iOS and Android do not ask for this permission. If notifications were allowed — on the website, in the Android app that is currently in Google Play (it is our website in a Chrome shell and works the same way), or earlier in an older version of the iOS app (the permission survives app updates) — then after you sign in we store the notification token of that browser or device, the device platform and your time zone, linked to your account, so that reminders could be sent at a suitable time. The token is issued by Google Firebase Cloud Messaging (website and Android) or by Apple Push Notification service (iOS). You can withdraw the permission at any time in your browser or device settings; the tokens are deleted together with your account.
• App updates — when the app starts, it checks for updates and sends our update service a random installation ID that does not identify you, the platform (iOS or Android), the version of the app's runtime and the update number; if an update fails to start, it also sends the error message.
• Support chat — when you open the support chat in the app or on the website, your messages and any files you attach are processed by our chat provider, Carrot Quest, and linked to your BeFluent account ID so that we can answer you.
• Feedback and problem reports — if you rate a feature or leave feedback in the app, or report a problem with a word or an exercise, we receive your message together with your email address and, for problem reports, technical details of your device (model, operating system version, text size setting, app version, and the last error).
• Purchases in the apps — see section 4.3.

Our new mobile apps for iOS and Android do not show advertising, do not contain advertising or analytics SDKs, do not use your device's advertising ID, and do not access your camera, microphone or location. The iOS app asks for access to your photos only if you choose a profile picture. Until the new Android app replaces it, the Android app currently in Google Play is our website in a Chrome shell: it works like the website and uses the same tools (Google Analytics, Yandex Metrica, Grafana Faro and Carrot Quest) under the cookie rules in section 16.

5. Obligation to provide up-to-date information

5.1. We rely on all information you provide being accurate, complete, and up to date. If your personal data changes (for example, your email address changes), you are required to notify us so that we can properly provide access to services and maintain the security of your account.

HOW WE USE YOUR DATA

6. Account management and service provision

We use your personal data to:

• Register your account and provide access to platform services.
• Operate your personal account, profile settings, and personalized content.
• Recover passwords and maintain account security.
• Contact you regarding your account, the services provided, and technical updates.

6.1. Improving the platform and personalizing learning

We analyze the collected data to:

• Optimize the interface, ease of navigation, and platform performance.
• Personalize the learning process by offering relevant materials, recommendations, and assignments based on your progress.
• Process your feedback and requests to improve the quality of our services.

6.2. Marketing purposes

We use your data for marketing in the following ways:

• Sending news, offers, and personalized recommendations to your email.
• Conducting surveys, promotions, and contests, and informing you about new courses or features.

To choose which emails to send you, our mail service uses your learning level, your subscription status, and your recent activity on the platform (see section 8.1).

We do not show advertising on our websites or in our apps, and we do not use advertising pixels, advertising cookies, or advertising identifiers.

6.3. When you create an account, we send you emails about your course and your learning, and occasional offers about BeFluent courses and subscriptions. You do not need to tick a box for this, and these emails are not required to use the platform: you can unsubscribe at any time with the "Unsubscribe" link included in every such email, or by writing to us at [email protected]. Unsubscribing does not affect your account or your access. Where the law of your country requires prior consent for such emails, we send them only with that consent. Even after you unsubscribe, we may send you service notices (for example, password reset, payment and subscription notices, important platform updates, or account security notifications).

7. Analysis of user behavior on the platform

We collect data about platform usage to:

• Track interaction with courses, tests, and other features and understand which materials are most useful.
• Identify technical errors, failures, and other issues in order to resolve them promptly.
• Analyze overall user statistics, which helps us develop the platform and adapt content to learners' real needs.

Analytical data is processed in pseudonymized form: we do not send your name or email address to analytics tools. Where an event has to be linked to a person (for example, the start of a free trial), we use a one-way code derived from the email address instead of the address itself.

Our new mobile apps do not contain analytics tools. Analytics (Google Analytics and Yandex Metrica) runs only on our websites, under the cookie rules in section 16, including in the Android app that is currently in Google Play (it is our website in a Chrome shell); when our web pages are opened inside the new iOS and Android apps, these tools are not loaded.

SHARING DATA WITH THIRD PARTIES

8. External services (Google Analytics, payment systems, etc.)

8.1. To ensure the stable operation of the platform and improve the user experience, we use third-party services that may receive a limited amount of data about you:

• Google Analytics — collects pseudonymized data about visits and interactions (pages, session time, devices). When you start a free trial, our server also sends Google Analytics a trial-start event linked to a one-way code derived from your email address, never the address itself. This helps us analyze user activity and optimize the platform.
• Yandex Metrica — on our websites only: pseudonymized data about visits and clicks (pages, session time, devices); session recording is turned off.
• Payment systems (Stripe, etc.) — if you make a payment, your data (card number, payment amount) is processed through secure payment gateways. We do not store or have access to full card details. They are stored by Stripe; the policy is available at: https://stripe.com/privacy.
• Email (our own mail service on Cloudflare, delivered by Mailgun) — all emails from the platform, both service messages (for example, password reset) and newsletters, are sent through our own mail service, which runs on Cloudflare, and delivered by Mailgun. To decide which emails to send you, our mail service keeps your email address, your account ID, your learning level, your subscription status, and your recent activity on the platform. We delete this profile when you delete your account.
• Subscription platforms (Apple App Store, Google Play) — if you purchase a subscription through third-party app stores such as Apple or Google, all payments and subscription management are handled directly by those platforms. We do not process such transactions and do not have access to payment data provided through Apple or Google. Therefore, any questions about refunds, payments, or subscription cancellation should be directed to the support of the relevant platform. When you delete your BeFluent account, we cancel your Google Play subscription automatically; an App Store subscription is not cancelled and must be cancelled in your Apple ID settings.
• Carrot Quest — the support chat in our apps and on the website: your messages, any files you attach, and your BeFluent account ID. Carrot Quest also determines your approximate city from your IP address.
• Google Firebase Cloud Messaging and Apple Push Notification service — if you allow notifications: issue the notification token of your browser or device (see section 4.6). Firebase is used on our learning website and in the Android app that is currently in Google Play; Apple's service in the iOS app. We do not currently send push notifications.
• PostHog — anonymous usage counts for the Russian level test at test.befluent.net (see section 17).
• Calendly — scheduling calls (BeFluent Premium): if you book a call, you enter your name and email address directly on Calendly's page, under Calendly's privacy policy.
• YouTube and Vimeo — some lessons contain embedded videos; when you play them, YouTube or Vimeo may receive your IP address and set cookies under their own policies.
• Infrastructure providers — DigitalOcean (our servers, database and file storage, including profile photos); Cloudflare (delivery and protection of our websites and services, and our mail service); Grafana Cloud (server logs and monitoring; on our learning website, Grafana Faro also records browser errors and page performance — your browser, operating system and the page address without parameters; logs contain no email addresses, names, or message text); Telegram (internal alerts to our team about errors and new learner feedback; feedback alerts include the learner's email address and the feedback text).

These providers process data on our behalf and according to our instructions.

9. Government authorities as required by law

In certain cases, we may share your data with government or law enforcement authorities if:

• We receive an official request in connection with legal proceedings or another legal process.
• It is necessary to fulfill our legal obligations, such as tax reporting or legal requirements.
• It is required to protect the rights, safety, and property of the platform or other users.

In all cases, data is shared only where there are proper and lawful grounds and safeguards.

LEGAL BASES AND INTERNATIONAL DATA TRANSFERS

10. Legal bases for processing

10.1. We process your personal data on the following legal bases (to the extent applicable to you depending on the laws of your jurisdiction):

• Performance of a contract — processing necessary to provide the Services you access (registration, account operation, access to content, subscription processing).
• Consent — where we expressly ask for it: for example, for analytics cookies on our websites where the law requires consent (section 16.1), and for the emails you request in the Russian level test (section 17.9). Consent may be withdrawn at any time.
• Legitimate interests — to ensure security, prevent abuse and fraud, improve and develop the platform, and send you emails about your course and offers about our courses, which you can unsubscribe from in every email (section 6.3), provided this does not override your rights and freedoms.
• Compliance with legal obligations — for example, for tax and financial reporting.

11. International data transfers

11.1. The Company is located in the United States, and some of our service providers (data processors) are also located in the United States or other countries. This means your data may be transferred outside your country of residence, including outside the European Economic Area (EEA) and the United Kingdom.

11.2. Where data of users from the EEA or the United Kingdom is transferred to countries that do not ensure an equivalent level of protection, such transfer is carried out on the basis of Standard Contractual Clauses (SCCs) included in data processing agreements with the relevant providers, or on the basis of another lawful transfer mechanism.

HOW WE STORE AND PROTECT YOUR DATA

12. Security measures

12.1. We take reasonable and appropriate measures to protect your data and prevent unauthorized access, disclosure, or alteration. However, no method of transmitting data over the internet and no method of electronic storage is completely secure, and we cannot guarantee the absolute security of information.

12.2. Where data is stored

• Cloud services — most user data is stored on secure servers of cloud providers that comply with international security standards (DigitalOcean; our websites and mail service run on Cloudflare).
• Local servers — in certain cases, data may be stored on local servers for backup and enhanced security.
• Payment data — is not stored on our servers; it is processed through certified payment gateways that comply with the PCI DSS standard.

12.3. Security measures applied

We apply reasonable organizational and technical security measures, which may include, among others:

• Encryption of transmitted data using SSL/TLS protocols.
• Access restriction — access to data is granted only to authorized employees in accordance with confidentiality rules.
• Use of authentication measures to protect access to admin panels and databases.
• Monitoring and protection of servers, including logging and analysis of suspicious activity.
• Regular backups to enable recovery in the event of failures.

The measures listed describe our approach to security and do not constitute a guarantee that each of them is applied at all times or that they fully eliminate all risks.

12.4. Retention periods and data deletion

We retain personal data only for as long as necessary, depending on the type of information:

• User accounts — data is stored while the account is active. When you delete your account yourself — in the app (Profile → Account → Delete account) or on the website (Profile → Delete account) — it is deleted immediately; profile photo files and your profile in our mail service are removed within minutes after that. If you ask us to delete your account by email, we do it within 30 days. Details: https://learn.befluent.net/delete-account.
• Financial and payment data — stored for the periods established by tax and financial law. Notifications from payment providers (Google Play, Apple, Stripe) about your subscription are kept for 90 days and then deleted automatically.
• Learning history (courses, tests, assignments) — stored while your account exists and deleted together with your account.
• After your account is deleted, we keep only: your email address and the date of deletion, with nothing else attached, so that the free trial is provided only once per email address (kept for as long as we offer a free trial); your support chat history (Carrot Quest) and feedback you sent to our team — until you ask us to delete them.
• Log files and analytics — server logs are masked (they contain no email addresses, names, or message text) and are kept for up to 30 days; pseudonymized analytics data in Google Analytics is kept for up to 14 months, after which it is deleted or retained solely in aggregated (non-personally identifiable) form.
• Backups — database backups are kept for 7 days and then overwritten; deleted data disappears from them within that time.

12.5. If a user requests deletion of their data, we will fulfill the request within 30 days, except where retention is required by law.

YOUR RIGHTS

13. Your rights regarding personal data

We give you control over your personal data and comply with applicable data protection requirements. Depending on your jurisdiction, you have the following rights:

• Right of access — request a copy of the data we hold, including personal information, learning history, and profile settings.
• Right to rectification — update or correct data if it is outdated, inaccurate, or incomplete.
• Right to erasure — delete your account and associated data yourself at any time, in the app or on the website (see https://learn.befluent.net/delete-account), or ask us to do it, except for data we are required to retain by law (for example, financial records) and the limited data described in section 12.4.
• Right to restriction of processing — request restriction of processing in cases provided by law.
• Right to data portability — receive your data in a structured, machine-readable format.
• Right to object — object to processing based on our legitimate interests, as well as to processing for direct marketing purposes.
• Right to withdraw consent — if processing is based on consent, you may withdraw it at any time, which does not affect the lawfulness of processing prior to withdrawal.

13.1. How to exercise your rights

To exercise any of these rights, write to us at [email protected]. We strive to respond within a reasonable time and, in any case, within the time frames established by applicable law (generally within 30 days; complex requests may require more time, of which we will notify you).

13.2. Opting out of marketing emails

You may opt out of marketing and promotional emails at any time: click "Unsubscribe" in any marketing email or write to us at [email protected], and we will remove you from marketing lists. Even after opting out, we may send service notices (for example, important platform updates or account security notifications).

14. Rights of California residents (CCPA/CPRA)

If you are a California resident, in addition to the rights listed above, you have the following rights under the California Consumer Privacy Act (CCPA), as amended by the CPRA:

• Right to know — which categories and specific pieces of personal information we collect, for what purposes, from which sources, and to which categories of third parties it is disclosed.
• Right to delete your personal information, except where it is required by law.
• Right to correct inaccurate personal information.
• Right to opt out of the "sale" or "sharing" of your personal information. We do not sell your personal information and do not share it for cross-context behavioral advertising: we do not use advertising cookies or advertising pixels. You can switch off analytics on our website at any time with "Cookie settings" in the footer of the site (see the "Cookies" section).
• Right to non-discrimination — we will not deny you services, change the price, or reduce the quality of services because you exercise your rights.

To exercise these rights, write to [email protected]. We may carry out reasonable verification of your identity before fulfilling a request. You may act through an authorized agent in the manner provided by law.

15. Right to lodge a complaint

If you believe we have processed your data improperly, you have the right to lodge a complaint with the data protection authority of your country. In the United Kingdom, this is the Information Commissioner's Office (ICO). We would appreciate it if you contacted us first so that we can try to resolve the matter directly.

COOKIES AND TRACKING TECHNOLOGIES

16. Cookies and tracking

We use cookies and other tracking technologies to ensure the proper operation of the site, improve the user experience, and personalize content.

16.1. Consent to the use of cookies

Strictly necessary (functional) cookies are set automatically, as the site does not work without them.

If you are visiting from the European Union, the European Economic Area, the United Kingdom or Switzerland, analytics cookies and any other cookies that are not strictly necessary are set only after we obtain your consent, through the cookie banner on your first visit. If we cannot tell where you are visiting from, we show you the banner as well.

If you are visiting from anywhere else, we turn on analytics (Google Analytics and Yandex Metrica) by default, without a banner. You can switch analytics off at any time with "Cookie settings" in the footer of the site: your choice is saved and we stop loading these tools.

In every case you may change or withdraw your choice at any time in the cookie settings.

16.2. What cookies we use

• Strictly necessary (functional) — needed for the site to work properly (for example, logging in, saving settings). They cannot be disabled, as the platform will not work correctly without them.
• Analytics — help us understand how users interact with the site (pages visited, time on site).
• Marketing — we do not currently use marketing or advertising cookies.
• Sign-in services — when you sign in with Google or Apple, those services may set their own cookies under their own policies.

16.3. How to disable cookies

You can manage cookies in your browser settings, for example:

• Google Chrome — Settings → Privacy and security → Cookies and other site data
• Mozilla Firefox — Settings → Privacy & Security → Cookies and Site Data
• Safari — Settings → Privacy → cookie settings
• Microsoft Edge — Settings → Cookies and site permissions

You can also use incognito/private browsing mode so that cookies are not saved after you close the browser.

16.4. Analytics tools

We use the following third-party analytics tools on our websites:

• Google Analytics — https://policies.google.com/privacy
• Yandex Metrica — https://yandex.com/legal/confidential/

We do not use Facebook Pixel, Google Ads, or other advertising networks on our websites.

Our own visit statistics. We also count visits to befluent.net with our own counter, which does not use cookies or store anything on your device. For each page view or click on a sign-up, level test or log-in link it records the page, the page where your visit started, the campaign tags in the link you followed (utm parameters), the website you came from (domain only), your country (determined by our hosting provider, Cloudflare; your IP address is not stored) and the type of device. It does not assign you an identifier and does not link visits together, so we see totals, not individual visitors. Individual records are kept for 90 days; daily totals are kept without a time limit. The data is stored on Cloudflare (our email and analytics service at a.befluent.net).

Learning in another language. If your browser language is not English, the home page and blog articles may ask whether you would rather learn Russian in your language. The same counter records whether the question was shown, closed or answered, with the language, page, country and type of device, and whether you clicked a sign-up link on that page. If you leave your email, we store it with the language and country and use it only to tell you when lessons in that language are ready. If you close the question or leave your email, your browser remembers it (local storage, key bf_lang_banner) so the question is not shown again. To have your email removed, write to [email protected].

16.5. How to opt out of analytics

You can:

• Switch analytics off with "Cookie settings" in the footer of the site.
• Install the Google Analytics opt-out browser add-on: https://tools.google.com/dlpage/gaoptout.
• Block or delete cookies in your browser settings (see section 16.3).

16.6. Mobile apps

Sections 16.1–16.5 apply to our websites. Our new mobile apps for iOS and Android do not use cookies or tracking pixels for advertising, do not contain advertising or analytics SDKs, do not show ads, and do not use your device's advertising ID. When the app opens a page of our website befluent.net (for example, this Privacy Policy), the page does not load Google Analytics or Yandex Metrica and does not show the cookie banner; right after the iOS app is first installed, until it has downloaded its first update (applied at the second launch), such a page may still load them. The Android app that is currently in Google Play is our website in a Chrome shell, so sections 16.1–16.5 apply to it in full.

RUSSIAN LEVEL TEST

17. The Russian level test (test.befluent.net)

The test at test.befluent.net tells you your Russian level and emails you a breakdown of where your gaps are. This section explains what it collects.

17.1. Until you type your email, we don't know who you are. The test runs entirely in your browser. Your answers, your score, and your level are worked out on your device and are never sent to us — not while you answer, not when you see your result. The share card is drawn in your browser too; the image is never uploaded anywhere.

17.2. When you ask for your breakdown, you give us your email address and tick a box agreeing to receive your results, learning tips, and occasional offers from BeFluent. At that point we send to our own mail service:

• your email address;
• your level, your sub-level, and your level in each of the three skills (vocabulary, cases, verbs);
• which skill came out weakest;
• the date you took the test and how many times you have taken it;
• the text of the breakdown itself — the specific gaps the test found in your answers, worded for the email.

We do not store your individual answers, and the record above lives in our own mail service, which runs on Cloudflare, and nowhere else.

17.3. To keep the form from being abused, our server briefly stores your IP address — on its own, with nothing attached to it — for one hour. If our mail service is unavailable when you submit, your address and results are held for up to 30 days so that we can still send the email we promised you; after that they are deleted automatically.

17.4. Analytics

We count how far people get through the test — the page loaded, the test started, the test finished, the email form seen, the email submitted, the plan button used, the share button used. These counts carry your level, not your identity: your email address is never attached to any of them, and the identifier used is a random string generated by your browser. We use PostHog for this, on their US servers. It sets no cookies and stores nothing on your device.

17.5. Browser local storage

Your browser stores five things, all of them on your device only: the random identifier described above; your progress through the test so a reload doesn't lose it; a copy of the analytics counts for debugging; any submission that failed to reach us so it can be retried; and the source of your first visit to the test (the UTM tags of the link you came from, such as the video or post), kept for up to 90 days so it can be passed on to the sign-up page when you choose to start your plan. Clearing your browser storage removes all five.

17.6. Who processes your data

Who	What they hold	Where
Mailgun — email sending	Your email address and the emails we send you	United States
PostHog — analytics	Anonymous usage counts, random browser identifier	United States
Cloudflare — hosting and our mail service	Serves the site; keeps your email address and test results in our mail service; briefly holds your IP address for abuse prevention	Global network

All three are processors acting on our instructions under a data processing agreement. Because they are US-based, your data is transferred outside the EU and the UK; those transfers rely on the Standard Contractual Clauses in each provider's data processing agreement.

17.7. How long we keep it

Your email address and results stay with us until you unsubscribe or ask us to delete them. The two temporary records described above — the IP address and the held submission — delete themselves after one hour and 30 days respectively.

17.8. Your choices

Unsubscribe with the link at the bottom of any email we send. One click, no questions, and it takes effect immediately.

Ask us to delete everything by emailing [email protected]. We will remove your address and your results and confirm when it is done.

Unsubscribing stops the emails; deletion removes the record. If you retake the test after unsubscribing, we will not resubscribe you.

17.9. If you are in the EU or the UK

The legal basis for sending you the emails is your consent, given by ticking the box on the results screen. The legal basis for the one-hour IP record is our legitimate interest in keeping the form from being abused.

You can withdraw consent at any time — that is what the unsubscribe link does — and withdrawing it does not affect anything sent before. You also have the right to ask for a copy of what we hold, to have it corrected, to have it deleted, to have its use restricted, to receive it in a portable form, and to object to it being used. Write to [email protected] and we will answer within one month.

If you think we have handled your data badly, you can complain to your national data protection authority. In the UK that is the Information Commissioner's Office (ICO).

The data controller is BeFluent Company, 8834 Reseda Blvd PMB 3016, Northridge, CA 91324.

17.10. Cookies

The test uses no cookies and no tracking pixels. It stores five items in your browser's local storage, listed above — three of them are needed for the test to work, the fourth is a debugging copy of the anonymous counts, and the fifth is the source of your first visit, kept to attribute your sign-up. Because none of them tracks you across other websites, no cookie banner is shown.

POLICY REGARDING MINORS

18. Minors

18.1. Our Services are not intended for children under the age of 13, and we do not knowingly collect the personal data of such children. Registration by individuals under 13 is not permitted.

18.2. Some jurisdictions may set a higher age threshold for independent consent to data processing (for example, 16 in a number of EU countries). If you have not reached the age established by the laws of your country for independent consent, please do not use the platform without the involvement of a parent or legal guardian.

18.3. If we become aware that we have collected the personal data of a child under 13, we will take reasonable steps to delete such data and block the relevant account.

18.4. A parent or legal guardian may request deletion of a minor's account and personal data by writing to [email protected] and providing: the minor's first and last name; the account email or username; and the reason for the request. We will process the request within 30 days, unless we have a legal basis for retaining the data.

CHANGES TO THE PRIVACY POLICY

19. Updates

We may update this Privacy Policy from time to time to reflect changes in the law, our Services, or our data processing practices.

19.1. How often the document is updated

• We review this Policy at least once a year, or more often if necessary.
• Updates may occur due to new features, changes in data processing, or legal requirements.
• The date of the last update is indicated at the beginning of the document.

19.2. How we notify users

If we make material changes, we may: post a notice on the site or platform; send an email to registered users (if we have contact information); indicate the effective date in the updated text.

19.3. Important

• Continued use of the Services after the changes take effect means your acceptance of the updated policy.
• If you do not agree, you may discontinue use of the platform and request deletion of your data.

TERMS OF USE FOR BEFLUENT AND BEFLUENT CAMP ONLINE PRODUCTS

GENERAL PROVISIONS

20. Scope

These Terms of Use govern access to and use of the platform, including websites, mobile applications, and other related services and educational initiatives of BeFluent Company.

20.1. By registering on the platform, the user agrees to these Terms.

20.2. Before registering on the platform or using any Company product, the user must review these Terms of Use and the Privacy Policy.

20.3. When creating an account on any site, application, or other educational initiative of the Company, the user confirms acceptance of these documents by creating the account (for example, by tapping or clicking "Sign Up", next to which these documents are linked).

20.4. If the user does not agree with any of the provisions, they may not register or use the platform.

20.5. The user's consent includes:

• Permission to process personal data in accordance with the Privacy Policy.
• Acceptance of the platform's rules of use, including age restrictions and the procedure for using the services.
• The administration reserves the right to refuse registration or block an account if violations are identified.

Continued use after registration means full and unconditional acceptance of these Terms of Use and the Privacy Policy.

21. Registration and account

21.1. Data required for registration

To create an account, the user must provide:

• A valid email address;
• A password that meets security requirements.

A first and last name is optional and can be added in the profile at any time.

When logging in via Apple or Google, the platform gains access to publicly available profile data (name, if available, and email).

The user must provide only accurate information. If false data is identified, the account may be blocked at the administration's discretion.

21.2. Account deletion or blocking

The user may delete the account at any time: in the app — Profile → Account → Delete account; on the website — sign in at learn.befluent.net and choose Profile → Delete account. The account and the data linked to it are deleted immediately. The user may also request account deletion by writing to [email protected] from the email address used for registration; we will delete the account within 30 days, except where retention is required by law (for example, retention of payment records). Step-by-step instructions and the full list of what is deleted and what is kept: https://learn.befluent.net/delete-account.

When an account is deleted, we automatically cancel its Google Play subscription and the automatic renewal of a subscription paid on our website, without a refund for the current period. An App Store subscription is not cancelled — cancel it in your Apple ID settings before deleting the account.

After deletion we keep only: the email address and the date of deletion, so that the free trial is provided only once per email address; payment records, where retention is required by law; and the other limited data listed in section 12.4.

An account may be temporarily or permanently blocked if the user: violates these Terms or the Privacy Policy; uses the platform for fraudulent purposes; distributes prohibited content, insults other users, or engages in other actions contrary to the platform's rules.

21.3. Re-registration and account transfer

Re-registration after blocking is possible only with the administration's permission. Accounts are personal and non-transferable: the user may not sell, give away, or transfer the account to another person. If the administration determines that an account is being used by another person, it may be blocked.

The user is fully responsible for account security. If account credentials are compromised (for example, hacking), the user must contact support immediately.

PAYMENT FOR SUBSCRIPTIONS ON THE BEFLUENT PLATFORM

22. Payment methods and subscriptions

We offer several payment and subscription options for accessing platform materials and additional features.

22.1. Payment methods

• Bank cards (Visa, MasterCard, American Express, etc.)
• On our website — through Stripe (cards, Apple Pay, Google Pay where available).
• In our mobile apps — through the Apple App Store or Google Play.

22.2. Subscription types

• One-time purchase — access to a specific course or material, with no recurring charge and no renewal.
• Recurring subscriptions of 1 month or 12 months — the full price of the chosen period is charged up front, and the subscription renews automatically for the same period unless cancelled. The 12-month (annual) subscription is billed as a single payment for the entire year and renews once per year.
• Trial version — a free subscription that provides unlimited access to BeFluent Basic privileges for 3 days; thereafter, charges are applied to the card linked by the user during trial registration.

22.3. Automatic renewal and cancellation

All recurring subscriptions renew automatically at the end of each paid period (monthly or annually) using the payment method on file, at the then-current price, until you cancel.

You can cancel at any time:

• If you subscribed directly through BeFluent, cancel in your profile settings.
• If you subscribed through the Apple App Store or Google Play, you must cancel through that store, because the payment is fully managed by Apple or Google. The only exception: when you delete your BeFluent account, we cancel your Google Play subscription automatically (see section 21.2). We cannot cancel an App Store subscription for you.

Cancellation stops future renewals. You keep access until the end of the period you have already paid for; no refund is issued for the unused time (see section 23).

22.4. Important: payments are processed through the payment services listed above, and we do not store full card details.

23. Payment policy on the BeFluent platform

23.1. During the BeFluent Premium trial period, the "Online lesson" privilege is unavailable. You must wait until the trial period ends and the subscription is paid, or pay early.

23.2. During the BeFluent Premium trial period, BeFluent Camp privileges are unavailable. You must wait until the trial period ends and the subscription is paid, or pay early.

23.3. All payments are non-refundable; refunds or compensation for virtual goods or partially used subscription periods are not provided, except where required by the laws of your jurisdiction. This applies equally to monthly and annual subscriptions. If you cancel a paid BeFluent subscription, you keep access until the end of the current paid period. Please note: if you made purchases in BeFluent through the Apple App Store or Google Play, payment processing is carried out by Apple or Google respectively.

24. Payment policy for the BeFluent Camp educational initiative

24.1. During the BeFluent Premium trial period, BeFluent Camp privileges are unavailable. You must wait until the trial period ends and the subscription is paid, or pay early.

24.2. A refund is available within 7 calendar days from the start date of the current BeFluent Camp cohort.

How to request a refund: email us at [email protected].

USER OBLIGATIONS

25. Prohibited actions

The following actions are prohibited:

• Fraud and deception — misleading the administration, teachers, or other users (for example, providing false data or impersonating another person).
• Copyright infringement — copying, distributing, or using platform materials without permission (courses, videos, tests, learning materials, and other educational resources).
• Insults and discrimination — using offensive language, inciting hatred, or discriminating on any basis (race, nationality, religion, gender, etc.).
• Spam and advertising — using the platform to send unsolicited advertising, links to third-party resources, or viruses.
• Unauthorized access and hacking — attempts to hack accounts, bypass security systems, or test the platform for vulnerabilities without permission.

If a violation is identified, the administration reserves the right to block the user's account without a refund.

26. Use of platform materials (personal and commercial)

Personal use: all materials are provided solely for personal learning. The user is granted a limited, non-exclusive, non-transferable license to use the content, without the right to distribute it.

Commercial use is prohibited. The user may not:

• Sell, distribute, copy, or transfer materials to third parties.
• Publish, upload, or make publicly available (including on social networks, file-sharing services, forums, and other platforms) any content obtained during the learning process.
• Use the platform's educational resources in third-party commercial projects.
• Conduct classes using the platform's materials or other educational initiatives of the Company.

27. Consequences of violation

Violation of these terms is considered unlawful use of the Company's intellectual property. In such cases, the Company reserves the right to:

• File a claim for copyright infringement and recovery of damages.
• Block the violator's account without restoration or refund.
• Provide information about the violator to law enforcement authorities in cases of large-scale or systematic piracy.
• Send an official demand to cease the violation, with the possibility of further legal action.

27.1. Warning: unlawful use of platform materials may result in civil, administrative, and criminal liability in accordance with applicable law.

ACCESS TO CONTENT AND ITS USE

28. Ownership of materials

All materials presented on the platform are the intellectual property of the Company and are governed by these Terms of Use.

28.1. Availability after the subscription ends

• Depending on the subscription type, the user may be granted limited or full access to materials.
• If the subscription period expires, access to premium materials (courses, video lessons, tests, additional materials) may be restricted.
• One-time purchases (for example, a course without a subscription) may remain available without a time limit (or for 4 months when using BeFluent Camp), unless otherwise stated in the product description.
• The user may not demand continued access after the subscription ends without payment for the next period.
• The Company reserves the right to change the terms of access to content depending on Company policy and the development of the platform.

29. Whether downloading or copying content is allowed

29.1. Downloading, copying, distributing, or otherwise reproducing platform content without explicit permission is prohibited.

29.2. Users may not upload, distribute, transfer, or publish learning materials on third-party resources (including social networks, file-sharing services, or forums).

29.3. Materials may be used only for personal educational purposes, without transfer to third parties.

29.4. The platform may provide a limited ability to download certain files (for example, PDFs), but their further distribution is prohibited.

29.5. For violations, the Company reserves the right to file a copyright protection claim and block the user's account without a refund.

30. Copyright in courses and materials

30.1. All courses, video lessons, learning materials, articles, tests, and other educational resources are the intellectual property of the Company.

30.2. Any commercial use, including resale, publication, or translation without permission, is a copyright infringement.

30.3. The user does not acquire ownership of the content, but only a license to use it within the platform.

30.4. Logos, branding, design, and other elements of the platform are also protected by copyright.

LIMITATION OF LIABILITY

31. Platform operation and outages

We make every effort to ensure the uninterrupted operation of the platform. However, in rare cases, technical failures may occur, and one hundred percent uninterrupted operation of any digital service cannot be guaranteed.

31.1. We strive to ensure the uninterrupted operation of the platform and other educational initiatives of the Company, but we cannot guarantee that the service will always be available without errors.

31.2. The administration is not responsible for temporary failures, delays, or data loss caused by:

• Technical problems with servers or hosting.
• Failures of the user's internet connection.
• Hacker attacks or the actions of third parties.
• Platform updates or maintenance.

31.3. We reserve the right to temporarily suspend services to resolve technical problems without prior notice.

31.4. If a failure affects access to paid content, the matter is resolved individually through support.

31.5. The Company is not responsible for losses caused by technical problems on the platform, or for failures resulting from force majeure circumstances.

32. Disclaimer of learning results

32.1. We provide educational tools, but we do not guarantee that the user will reach a particular level of language proficiency.

32.2. Learning success depends on the personal effort, engagement, consistency, and completion of assignments by the user.

32.3. Any results presented on the platform (for example, examples of other learners' successes) are informational in nature and do not guarantee similar results for every user.

32.4. The Company is not responsible for: failure to achieve expected learning results; errors in materials (we strive to promptly correct inaccuracies when they are discovered); the use of knowledge gained on the platform in professional or academic activities.

Learning on the platform is a tool, but the final result depends on the user.

33. General limitation of liability

33.1. The Services are provided on an "as is" and "as available" basis, without any express or implied warranties, to the maximum extent permitted by applicable law.

33.2. To the maximum extent permitted by law, the Company, its employees, teachers, and partners are not liable for any indirect, incidental, punitive, or consequential damages, including lost profits, loss of data, or loss of business reputation, arising in connection with the use of or inability to use the Services.

33.3. To the maximum extent permitted by law, the Company's total liability for any claims related to the Services is limited to the amount actually paid by you to the Company during the 12 (twelve) months preceding the event giving rise to the claim.

33.4. Nothing in these Terms excludes or limits liability to the extent that such exclusion or limitation is prohibited by applicable law (including liability that cannot be limited with respect to consumers).

34. Indemnification by the user

34.1. The user agrees to indemnify the Company, its employees, and partners for reasonable damages, liabilities, and expenses (including reasonable legal fees) arising from the user's breach of these Terms of Use, infringement of third-party rights, or misuse of the Services.

35. Force majeure

35.1. The Company is not liable for failure to perform or delay in performing its obligations caused by circumstances beyond its reasonable control, including, but not limited to, natural disasters, failures of the internet or hosting providers, cyberattacks, actions of government authorities, or interruptions in power or communications.

GOVERNING LAW AND DISPUTE RESOLUTION

36. Governing law

36.1. These Terms of Use and the Privacy Policy are governed by the laws of the State of California and applicable US federal law, without regard to conflict-of-laws rules. This provision does not deprive consumers of the protection guaranteed by the mandatory provisions of the law of their country of residence.

37. Dispute resolution and arbitration

37.1. To the extent permitted by applicable law, disputes arising out of or in connection with these Terms are resolved through individual binding arbitration rather than in court, except for disputes that may be heard in small claims court.

37.2. To the extent permitted by law, you and the Company waive participation in class (collective) actions and agree to bring claims against each other only on an individual basis.

37.3. This section does not apply to the extent that mandatory arbitration or a class action waiver is prohibited by applicable law. In particular, if you are a consumer in the EU or the UK, you retain the right to protection in the competent courts of your place of residence, and nothing in this section deprives you of that right.

37.4. Before initiating formal proceedings, we ask you to contact us at [email protected] so that we can try to resolve the matter out of court.

CHANGES TO THE TERMS OF USE

38. Updates

We reserve the right to change these Terms of Use at any time in connection with changes in the law, platform updates, or new security requirements.

38.1. We regularly review and update the Terms — at least once a year or as needed.

Updates may occur in the following cases: the introduction of new features; changes in the laws governing data processing or educational services; adjustments to the payment, subscription, or content-use policy; strengthening of data protection and user security measures. The date of the last update is always indicated at the beginning of the document.

Important: continued use of the platform after the changes take effect means acceptance of the updated terms.

How users are notified:

• Minor changes (for example, clarifications of wording) may take effect without separate notice.
• We may notify you of material changes (payment, access conditions, user rights) through: an email to the address provided at registration; a notice on the site or in your personal account; a pop-up notification upon login; and, in some cases, we may request renewed consent.

If the user does not agree with the updated terms, they may discontinue use of the platform and request account deletion.

CONTACT INFORMATION

39. How to contact us

Primary email: [email protected]

We strive to respond to all inquiries within a reasonable time, generally within 24 hours, excluding weekends and holidays.

BeFluent Company

8834 Reseda Blvd PMB 3016

Northridge, CA 91324

USA