LingoflyWebsite Privacy Policy and GDPR
This page answers the questions the GDPR requires to be disclosed at the moment of collection: who processes the data, what exactly is collected, on what grounds, how long it is kept and what your rights are. In short: the site's own statistics contain no IP address, no cookies, no identifier of any kind, and third-party counters load only after your consent — never earlier.
App Privacy Policy
Learning data, purchases, voice, analytics consent and account deletion are described in the App Privacy Policy. The rest of this page describes website visitor data.
Who processes data, and on what grounds
The data controller is Zorqubit Labs LLC (Lingofly); contact is by email at support@zqbl.org.
The company is registered in Missouri, United States. Company website: [zqbl.org](https://zqbl.org/).
The site's own statistics contain no identifiers: no IP address, no cookies, no device fingerprint, no link between events. We describe it here because a field list is the simplest way to show it.
The traffic counters run on consent (art. 6(1)(a) GDPR): they do not load until you have pressed “I agree”, and a refusal is remembered the same way as consent. Consent is voluntary — if you refuse, the site works in full.
Which data is processed
| What | What exactly is recorded | What for |
|---|---|---|
| An on-page event | page kind, section language, interface language, event time and fixed values: scroll depth, answer result, button placement and destination | to see which sections get read and where people leave for the app |
| A site search query | the number of pages found and the interface language; the query text is not recorded | to see how often a search finds nothing |
| Your answer about the counters | a single “yes” or “no” in the browser's memory (localStorage), on your device | so we do not ask twice |
What our own statistics do not record
- Your IP address — neither in the open nor as a hash. A hash of an address remains a pointer to a person if the set of addresses can be enumerated, and it can.
- Cookies and any persistent identifier. An event is linked neither to the one before nor to the one after: there is nothing to link it with.
- Where you came from — the referrer header is not kept.
- Recording your actions on the page — mouse movements, scrolling as a track, clicks on elements. None of that exists in our own analytics or in the settings of third-party counters.
- Data from the app. The site and the app are separate systems; lessons, streaks and payments live in the app and never travel to the site.
Counters and transfers outside the EU
The traffic counters — Yandex.Metrica and Google Analytics — are connected only after you consent. Until you press “I agree”, the browser does not contact their addresses at all: the page carries none of their tags, and the script is created only after the press.
If you agreed, the counter places its own identifiers on the device and processes data by its owner's rules — not by ours. Recording actions on the page (Metrica's webvisor and click map) is switched off by us explicitly.
We ourselves tell the counters only one thing: that you pressed the button that takes you to the app, and where on the page it was. That shows which pages bring people to the app, not just which ones get read. Besides that, Metrica records clicks on links to other sites and file downloads on its own — we keep that setting switched on.
A refusal is remembered the same way as consent: we will not ask a second time. To change your mind, clear the site's data in the browser settings — the question will then appear again.
If you consent, a counter's data goes to its owner and is processed under the owner's rules — and both mean a transfer outside the EEA: Yandex.Metrica processes data on Yandex servers in Russia, Google Analytics in Google's infrastructure, including outside the EEA. That is exactly what consent is asked for; declining leaves you out of both transfers.
Retention periods
Events are stored as files on the same server as the site and are deleted after 180 days — the server itself does this at the change of day, not a person following a reminder.
Separately from the statistics, the proxy server that delivers the site keeps a technical request log — every web server does. The log holds the IP address, the time, the page address, the request headers (including the browser and the page you came from) and the server's response. It shows errors and search-engine crawlers; it is not linked to the statistics events, is not used to watch people and is deleted automatically after 30 days.
Rights under the GDPR
- Access (art. 15): find out what is being processed about you.
- Rectification (art. 16) and erasure (art. 17).
- Restriction of processing (art. 18) and objection (art. 21).
- Portability (art. 20) — for data you provided yourself.
- Withdrawal of consent at any time (art. 7(3)) — it does not affect the lawfulness of processing before the withdrawal.
- Complaint to a supervisory authority (art. 77) — in the country where you live.
No automated decisions
The site makes no automated decisions about you with legal or similar effects (art. 22 GDPR) and builds no profiles: there is nothing to build them from.
Frequently asked
Does the site set cookies?
The site's own part — not a single one. The only thing stored on your device is your answer about the counters in the browser's memory. If you agreed to the counters, it is they who place their identifiers.
Who is the data controller?
Zorqubit Labs LLC (Lingofly). Letters about data processing go to support@zqbl.org; the reply comes to the same address.
Is data transferred outside the EEA?
Only through the counters and only with your consent — but through both: Yandex.Metrica processes data on Yandex servers in Russia, Google Analytics also outside the EEA. Without consent not a single request goes to their addresses.
Can I demand deletion of my data?
Withdrawing consent to the counters — yes, at any moment. As for statistics events, they are tied to a person by no field, so singling out yours is impossible: that is the price of our not recording an identifier.
What happens if I refuse?
Nothing changes: pages, recordings, trainers and search work the same. We simply will not learn which pages bring people in — and that is our problem, not yours.