PRIVACY POLICY

Last updated: 27.07.2026

Introduction

This Privacy Policy is intended to inform users of the website https://www.labarile-languages.com (the "Site") how their personal data is collected, used, retained, and protected.

Because we serve an international audience, this Policy is designed to comply with the applicable data-protection frameworks that may govern our relationship with you, including:

• the General Data Protection Regulation (EU) 2016/679 ("GDPR") and the UK GDPR, for users located in the European Economic Area (EEA) and the United Kingdom;
• the California Consumer Privacy Act as amended by the California Privacy Rights Act ("CCPA/CPRA") and comparable U.S. state privacy laws, for users located in the United States;
• applicable United States federal and Wyoming state law.

This Policy also sets out the rights available to data subjects, as well as the ways to exercise those rights with the data controller.

ARTICLE 1 – Identity and Contact Details of the Data Controller

Personal data collected through https://www.labarile-languages.com is processed by:

Company name: LL Languages LLC

Legal form: Wyoming Limited Liability Company (LLC)

Registered / principal office: 30 N Gould St, Ste R, Sheridan, WY 82801, United States of America

Wyoming Filing ID: 2026-002025572

Contact email: support@labarilelanguages.com

LL Languages LLC, in its capacity as data controller (and as a "business" under the CCPA/CPRA), determines the purposes and means of processing the personal data of Site users.

ARTICLE 2 – Data Protection Contact

We are not legally required to appoint a Data Protection Officer (DPO) for the activity we carry out, and no DPO has been designated. However, for any question relating to the protection of your personal data or the exercise of your rights (access, rectification, erasure, objection, restriction, portability), you may contact the data controller directly at:

Email: support@labarilelanguages.com

Postal address: 30 N Gould St, Ste R, Sheridan, WY 82801, United States of America

ARTICLE 3 – Data Collected

In connection with the use of the Site, LL Languages LLC may collect and process the following categories of data:

• Identification data: last name, first name, postal address, email address, telephone number.
• Order and contractual-relationship data: information on products ordered, quantities, prices, billing, purchase history, after-sales service requests.
• Payment data: banking or payment-card details (this data is processed securely by approved payment-service providers and is not retained by LL Languages LLC, except with the client's express agreement where regulation permits).
• Connection, browsing, and technical data: IP address, connection identifiers, browser type, navigation within the member area/Skool, information from cookies and trackers (see the "Cookies" section).
• Data necessary to comply with legal or regulatory obligations: notably tax, accounting, or fraud-prevention obligations.
• Any other information voluntarily provided by the user in connection with the performance of the contract or their exchanges with the Seller, such as educational data (progress, exercise results, interactions with coaches and the community).

The services are not intended for children. Where applicable law requires it (notably for online services offered directly to a child), the processing of the data of a child below the applicable digital-consent age is subject to the authorization of the holder of parental authority. LL Languages LLC may carry out a reasonable verification of this authorization, and in the event of unintentional collection, the data will be deleted upon notification.

ARTICLE 4 – Purposes and Legal Bases of Processing

LL Languages LLC processes users' personal data for the purposes set out below. For users protected by the GDPR, the relevant legal basis is indicated.

• Creating and managing client accounts and the student area, enabling access to courses and educational resources, tracking progress, and issuing certificates where applicable. *Legal basis (GDPR): performance of the contract (Art. 6(1)(b)).*
• Organizing and delivering courses and coaching, whether in person or by videoconference, including scheduling, teacher assignment, sending materials, and educational exchanges. *Legal basis (GDPR): performance of the contract (Art. 6(1)(b)).*
• Supplying digital content and educational personalization (adaptation to level and objectives, exercises, and corrections). Certain data may, strictly as necessary, be used to improve educational quality and user experience. *Legal basis (GDPR): performance of the contract (Art. 6(1)(b)) and legitimate interest (Art. 6(1)(f)).*
• Managing the client relationship: responding to requests, providing technical assistance, handling returns and complaints, and measuring satisfaction. *Legal basis (GDPR): performance of the contract (Art. 6(1)(b)) and legitimate interest (Art. 6(1)(f)).*
• Managing orders, billing, and payments: processing purchases, issuing invoices, preventing unpaid amounts, and complying with accounting and tax obligations. *Legal basis (GDPR): performance of the contract (Art. 6(1)(b)) and legal obligation (Art. 6(1)(c)).*
• Ensuring Site security and preventing fraud or abuse through technical logging, anomaly detection, and protection of infrastructure and user accounts. *Legal basis (GDPR): legitimate interest (Art. 6(1)(f)).*
• Audience measurement and statistical analysis strictly necessary to operate and improve the Site. Where non-essential trackers are used, prior consent is sought. *Legal basis (GDPR): legitimate interest (Art. 6(1)(f)) or consent (Art. 6(1)(a)).*
• Marketing and newsletter communications to users who have given prior consent, which may be withdrawn at any time. For existing clients, we may also send communications about similar services on the basis of legitimate interest, with the option to opt out easily at any time. *Legal basis (GDPR): consent (Art. 6(1)(a)) or legitimate interest (Art. 6(1)(f)).*
• Operational, non-marketing communications necessary for the proper delivery of services (order confirmations, class reminders, schedule changes, or contractual updates). *Legal basis (GDPR): performance of the contract (Art. 6(1)(b)) or legal obligation (Art. 6(1)(c)).*
• Complying with legal and regulatory obligations, responding to authorities, managing disputes, and establishing, exercising, or defending legal claims. *Legal basis (GDPR): legal obligation (Art. 6(1)(c)) and/or legitimate interest (Art. 6(1)(f)).* Where identifying reviews or testimonials are published, prior consent is sought.

Where processing is based on legitimate interest, LL Languages LLC balances the interest pursued against the rights and freedoms of the data subjects, particularly regarding system and account security, fraud and abuse prevention, service quality, and continuous improvement.

LL Languages LLC does not use decisions taken solely by automated means producing legal effects or similarly significant effects. If such a mechanism were implemented, prior information would detail the applicable rights.

ARTICLE 5 – Recipients of the Data

The personal data collected is intended exclusively for LL Languages LLC and, where applicable, its strictly authorized subcontractors or contractual partners. Recipients may be:

1. Internal departments of LL Languages LLC responsible for order management, client relations, billing, and delivery tracking (including management of student accounts/areas, scheduling and delivery of in-person or videoconference courses, educational follow-up, and issuance of certificates).

2. Payment-service providers (banking institutions and approved providers such as Stripe, PayPal, or any other payment provider used) in connection with the secure processing of financial transactions.

3. Technical and IT service providers (hosts, maintenance services, providers of business-management or emailing solutions), acting as processors and bound by strict contractual confidentiality and security obligations.

4. Where applicable, competent administrative, tax, regulatory, or judicial authorities, where required by law or for the defense of the data controller's rights.

LL Languages LLC undertakes never to sell, rent, or trade its clients' personal data to third parties for purposes other than those described in this Policy. We do not "sell" or "share" personal information as those terms are defined under the CCPA/CPRA.

ARTICLE 6 – International Data Transfers

LL Languages LLC is established in the United States, and data may be processed and hosted in the United States and in other countries where our service providers operate, including within the EEA/Switzerland.

Where personal data of users located in the EEA, the United Kingdom, or Switzerland is transferred to a country not recognized as providing an adequate level of protection, LL Languages LLC undertakes that such transfers are carried out under appropriate safeguards, notably:

• the Standard Contractual Clauses (SCCs) adopted by the European Commission (and the UK/Swiss equivalents), supplemented where necessary by additional security measures (Art. 46 GDPR); or
• one of the derogations provided for in Article 49 GDPR (notably explicit consent of the data subject, performance of a contract, or establishment/exercise of legal claims).

In any event, users are informed of any transfer of their data to a third country and of the safeguards implemented to protect it. You may request a copy of the relevant safeguards by contacting us at the address above.

ARTICLE 7 – Data Retention Period

Personal data is retained by LL Languages LLC only for the period strictly necessary to achieve the purposes for which it was collected. For reference:

• Order and contractual-relationship data: retained for the duration of the contractual relationship, then archived for the applicable statutory limitation period.
• Billing data and legal obligations (accounting, tax): retained for the period required by applicable law, without prejudice to longer periods imposed by specific regulations.
• Data used for commercial prospecting (newsletters, offers): retained for up to 3 years from the last contact initiated by the data subject, unless consent is withdrawn or an objection is raised before that term. Proof of consent may be archived for compliance purposes.
• Banking / payment data: retained only for the time necessary for the transaction via the payment provider; for recurring payments, tokenized retention by the provider until termination or expiry of the payment method. LL Languages LLC does not retain full card details in plaintext.
• Cookies, browsing data, and technical logs: retention adapted to the purposes and Site settings; non-essential trackers are retained for a maximum of 12 months from placement (or less depending on settings) and are deleted upon withdrawal of consent.
• Data linked to a dispute or proceedings: retained until final resolution of the dispute, within the limits of applicable limitation periods.

At the end of the retention periods, the data is deleted or, where possible, irreversibly anonymized for statistical purposes only.

ARTICLE 8 – Rights of Data Subjects

For users protected by the GDPR / UK GDPR, you have the following rights over your personal data:

• Right of access: obtain confirmation that your personal data is being processed and, where applicable, receive a copy.
• Right to rectification: request the correction of inaccurate or incomplete data.
• Right to erasure ("right to be forgotten"): request the deletion of your data in the cases provided for by law.
• Right to restriction of processing: obtain the temporary suspension of processing in certain situations.
• Right to object: object, at any time, to processing based on the controller's legitimate interest or used for commercial prospecting.
• Right to data portability: receive the personal data you provided in a structured, commonly used, and machine-readable format, or request its transmission to another controller where technically feasible.
• Right to withdraw consent: at any time, for processing based on consent, without affecting the lawfulness of processing prior to withdrawal.

For users protected by the CCPA/CPRA (California and comparable U.S. states), you have the right to:

• Know what personal information is collected, used, disclosed, and the purposes;
• Access and obtain a copy of your personal information;
• Delete your personal information, subject to legal exceptions;
• Correct inaccurate personal information;
• Opt out of any "sale" or "sharing" of personal information (note: we do not sell or share personal information);
• Non-discrimination for exercising your privacy rights.

Exercising these rights is free of charge. The controller may nevertheless request the payment of reasonable fees in the event of manifestly unfounded or excessive requests. Requests may be sent:

• by email: support@labarilelanguages.com
• by mail: 30 N Gould St, Ste R, Sheridan, WY 82801, United States of America.

To protect the confidentiality of personal data, LL Languages LLC may request proof of identity before responding to a request. The controller undertakes to respond to any request within one month (GDPR) or within the timeframe required by applicable U.S. law, extendable in the event of particular complexity.

Complaints and supervisory authorities. In the event of an unresolved difficulty or dispute with LL Languages LLC:

• In the EEA: you may lodge a complaint with the supervisory authority of your Member State of habitual residence, place of work, or the place of the alleged infringement (Art. 77 GDPR).
• In the UK: you may contact the Information Commissioner's Office (ICO).
• In the United States: you may contact your state Attorney General where applicable.

ARTICLE 9 – Data Security

LL Languages LLC implements appropriate technical and organizational measures to guarantee the confidentiality, integrity, availability, and resilience of the personal data processed, in line with Article 32 GDPR and applicable security standards. These measures aim in particular to protect data against loss, accidental destruction, alteration, unauthorized access, or unlawful disclosure, and include, as applicable:

• the use of secure systems for the storage and transmission of data (encryption, SSL/TLS protocols);
• regular backup and recovery mechanisms;
• restriction of access to authorized persons only, subject to a confidentiality obligation;
• internal IT-security policies and staff-awareness measures;
• recourse to providers offering sufficient guarantees.

Payments are processed exclusively by PCI-DSS certified payment-service providers; no full banking data is stored by the Seller.

In the event of a personal-data breach presenting a risk to individuals, LL Languages LLC applies an internal detection, analysis, containment, remediation, and traceability procedure. Where required by the GDPR, LL Languages LLC notifies the competent data-protection authority as soon as possible, and at the latest 72 hours after becoming aware of it. Where the breach is likely to result in a high risk to individuals, LL Languages LLC also informs the affected persons without undue delay, and complies with applicable U.S. state breach-notification laws. Subcontractors are contractually required to report any breach immediately to LL Languages LLC, to cooperate with regulatory notifications, and to implement the necessary corrective measures.

ARTICLE 10 – Automated Decision-Making and Profiling

LL Languages LLC does not implement any individual decision taken solely by automated means, including profiling, producing legal effects concerning users or significantly affecting them within the meaning of Article 22 GDPR. Should such processing be implemented later, data subjects would be informed clearly and in advance and would then have the right to obtain human intervention, to express their point of view, and to contest the decision.

ARTICLE 11 – Cookies and Trackers

When browsing the Site, cookies and other trackers may be placed on the user's device in order to:

• Ensure the technical operation of the site and member area — Strictly necessary cookies: essential to the operation of the site (e.g., cart memorization, session management). Their placement does not require the user's prior consent.
• Measure audience and improve the user experience — Audience-measurement and statistical-analysis cookies: allow analysis of site traffic to improve performance. Their placement is subject to the user's consent.
• Personalize content — Personalization and targeted-advertising cookies: used to offer personalized content or adapted offers. Their placement is subject to the user's consent.

The maximum retention period for cookies is 13 months from their placement on the device. The user may accept, refuse, or configure the placement of cookies at any time using the cookie-management module made available on the site, and may withdraw consent as easily as it was given.

The user also retains the option to configure their browser to block all or part of cookies. However, certain features of the site may be degraded in the absence of necessary cookies.

ARTICLE 12 – Sources of the Data

In principle, personal data is collected directly from the data subject when browsing the Site or in connection with the contractual relationship with LL Languages LLC. Where data has not been collected directly from the data subject, its source will be specified upon the first communication or, at the latest, within one month of collection. Such data may come from commercial partners or providers involved in performing the contract (e.g., payment providers), from publicly accessible sources (professional directories, legal and administrative registers), or from other duly authorized third parties. In all cases, the data subject's rights remain fully applicable.

ARTICLE 13 – Modification of the Privacy Policy

This Policy may be modified at any time to reflect changes in regulations or processing operations. In the event of a substantial modification, users will be informed by a specific notice on a durable medium on the Site's home page or in their member area and, where applicable, by email. The date of the last update will always be indicated at the top of the document.