This Policy establishes safeguards for the processing of data and the interaction of children and adolescents within the Lingopass Ecosystem, as well as for vulnerable groups participating in the Empowering Talents program, guided by the best interests of the child and the “child rights by design” approach.
1.1. The protection of children and adolescents is a priority, taking precedence over commercial objectives, in accordance with the ECA, the LGPD (Art. 14), the GDPR (Art. 8), and UN General Comment No. 25 on the rights of the child in the digital environment.
2.1. The services are intended for individuals 18 years of age or older. Where use by minors is expressly permitted, the rules of this Policy and the local age limit apply (in the EU, 16 years of age, which may be lowered to 13 by individual Member States; in the U.S., 13 under COPPA).
2.2. Lingopass uses an age verification mechanism during registration and when accessing open rooms (such as Lingoverse), and does not rely solely on self-declaration.
3.1. For minors under the age limit, specific and prominent consent from at least one parent or legal guardian is required, with a reasonable verification method and traceable record.
4.1. For minors, the platform adopts a minimal data collection approach, more protective settings by default, and prohibits behavioral profiling, targeted advertising, and the sale or sharing of data.
5.1. Socioeconomic and diversity data processed by Empowering Talents are considered high-risk: strictly limited to the selection of scholarship recipients, short retention period, prohibition on commercial use, and preparation of a specific impact report (RIPD).
6.1. Moderation and protective measures are implemented for live classes and AI-powered features accessible to minors. The use of minors’ data for model training is prohibited.
7.1. The content and interactions are age-appropriate, and a review process is in place to ensure this.
8.1. Parents or guardians may access, correct, and request the deletion of a minor’s data, in accessible language, through a dedicated channel ([email protected]).
9.1. Data processing involving minors on a large scale or using AI is preceded by a specific RIPD/DPIA, which is reassessed in the event of relevant changes.
10.1. A designated contact person and a reporting channel ([email protected]) are in place. Incidents involving minors are handled and reported on a priority basis.
11.1. Privacy notices and terms relating to minors are written in clear language that is accessible to minors and their guardians.
12.1. This Policy takes effect upon approval and is reviewed annually or whenever significant changes occur.
