Updated: February 16th, 2025

Munay Live LLC (“Munay”) is committed to protecting your personal data. We tried to write this Privacy Policy in the most clear and plain language possible. Likewise, we tried to provide you with our privacy commitments in a transparent and easily accessible way. That said, we hope you will get all the needed details to be assured your personal data is safe with us.

Before you give us your consent on the processing of your personal data or provide us with your personal data within any form on our website, we kindly ask you to read this Privacy Policy carefully, so we can be sure that you completely understand the conditions under which we would cooperate together.

This Privacy Policy applies to your use of the Services of Munay, as defined in our Terms of Service. This Privacy Policy explains when, where, and why we process the personal data of people who use the Munay Platform, how we use it, the conditions under which we may disclose it to others, your rights in respect of your personal data, as well as how we keep it secure.

GENERAL

Access to the Munay Platform (including Website, related software and Munay mobile device application) is available with or without the necessity to register an account. You may access our Website without registration. Therefore, limited use of the Services is always possible without the provision of your personal details (for example, browse the Website, check how Munay works, look through the list of practitioners, review the variety of services, etc.). However, whenever you access the Website, we collect log information and put cookies on your device, by which we track your activity on the Website. You can always opt out of cookies except those without which the Website cannot work.

When you are a registered user, Munay may collect from you and process cookie identifiers and the data you specifically provide us with upon registration, including first name, last name, email, phone number, or social network ID (if assigned through Facebook or if accessing Google), time zone, interface language, IP address, and device type.

Specifically, if you are a practitioner, we may also collect and process, besides the aforementioned information, the other data provided by you, including zip code, year of birth, city of residence, and relevant experience.

Registered users may additionally provide profile pictures. You can find out more about the specific cases of data collection and the purposes of the processing of such data in a separate section of this Privacy Policy.

We may change this Privacy Policy from time to time, so please check this page to ensure that you’re happy with any changes. We will post those changes on this page and update the Privacy Policy modification date at the top of this page.

We may also occasionally experiment with different features of the Munay Platform which can affect the scope, purposes, or other details of the processing of personal data. In such cases we will provide prior notification and, if necessary, obtain your consent. Any questions regarding this Policy and our services should be sent to legal@munay.live.

What Is Personal Data and the Processing of Personal Data?

Personal data is any information relating to you that alone or in combination with other pieces of information allows a person that collects and processes such information to identify you as an individual.

Processing of the personal data means any operation with your personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Data subject is any identified or identifiable natural person whose personal data is processed by the controller responsible for the processing; means you as a user of Munay.

Consent of the data subject/user is any freely given, specific, informed, and unambiguous indication of the data subject/user’s wishes by which he or she, by a statement or by clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

Munay’s Lawful Bases for Processing Munay processes your personal data only when we have lawful bases.

Specifically, Munay processes your personal data if: processing is based on the consent you have given. As such our newsletters, collection, analysis, and publication of user feedback and reviews, translation and recording of video sessions, your participation in our events and webinars, and placement of different types of cookies; processing is necessary to provide our services to you according to our Terms of Service which constitute a contract between you and us as regards to information services of Munay; in particular, this concerns enhancing the learning experience for practitioners and customers by providing AI-powered personalized recommendations, improved journey planning, and interactive guidance tools; processing is based on the explicit consent you have given to us and our online verification provider to process your information for the purposes of practitioner identity verification and fraud identification; processing is necessary for the purposes of our legitimate interests. Those legitimate interests may include but are not limited to: compliance with the U.S. financial and accounting legislation; the assessment of Munay’s business efficiency by analyzing the Munay Platform traffic and financial performance indicators; promotion of Munay through social media networks, media outlets, referees andaffiliates, such as bloggers or influencers; this in particular concerns the right of Munay to use the practitioner's name, profile picture and other details for marketing, advertising or promotional purposes pursuant to the Terms of Service; performance of the contracts with Munay customers and provision of reports on their employees’ and contractors’ language learning progress and results of language assessment tests; user session control and fraud prevention, ensuring the appropriate protection of personal data; practitioner verification and development of high-quality services with customers; AI data training. where necessary, compliance with applicable legislation (e.g., data subject request processing); in exceptional cases, to protect your vital interests or vital interests of another natural person; or for the performance of a task carried out in the public interest or in the exercise of official authority vested in us. In all cases, we will notify you about the applied legal basis for processing and other relevant details before we start the processing of your personal data on a specific legal basis unless we are not able to do so in accordance with our obligations under any applicable legislation.

Data We Collect:

Scope Munay collects from you only the following information and only for the stated below purposes:

Account for Customers: Munay collects and processes personal data submitted by you upon registration and further editing of settings in your Account. For registration purposes, you submit your login credentials (username and password), first name, last name, and email.

Account for Practitioners: Munay collects and processes personal data submitted by you upon registration and further editing of your profile. For registration purposes, you submit your login credentials (username and password), first name, last name, and email. We may require you to provide proof of your qualifications, such as copies of your licenses and/or certificates, and registration. You may also edit your profile anytime with additional information as well as sync your Google and Munay Calendars. Such additional information may help you find a suitable time slot with a customer or have more visibility of your schedule. Some personal data, such as users’ names and location, that is listed in your user profiles or derived from IP addresses may be publicly visible to other users on the Services or to the web.

Posting of Information: We process personal data freely submitted to you on Munay. This may be a survey and online form you fill in on Munay, a question or comment left in the Q&A section of our Website, or feedback you provide us with. Munay may also process information provided by you (including content and messages) that you post on/through the Munay Platform, including personally identifiable information. By doing so, you acknowledge that any information you share through the Services will be available to Munay and to other users of the Services (customers/practitioners). You also acknowledge that parts of your content cannot be deleted from the Service as it may be connected to the services created by you and used by other users (customers/practitioners). From our turn and unless you opt out, we retain this information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law. We reserve the right to terminate the accounts of visitors who use these services in a manner inconsistent with the Terms of Service or User Code of Conduct.

Service Use, Cookies and Other Similar Technologies: When you use our Services, we monitor and analyze web traffic and keep track of your behavior.

Billing Information: We process the details of transactions you carry out through the Munay Platform (such as ID, date and time of transaction) through our 3rd partners such as Sharetribe, Wise and Stripe.

Sensitive Data: Unless you expressly agree, Munay does not process your sensitive data. Pages on Social Networks: We maintain Munay’s official pages on social networks, such as Facebook, Youtube, Instagram, Bluesky and LinkedIn. When you interact with Munay’s official pages in social networks, such as subscribing to the pages or leaving comments or reactions (e.g., ‘like’ our posts), we can analyze this data to measure our efficiency and conduct an analysis of our social media marketing campaigns in our legitimate interests.

Information Required for Submitting Tax Documentation: To comply with the applicable tax and accounting legislation, we may be required to submit various tax documentation containing your personal data. For example, a federal tax form 1099 or such other required tax form(s) necessary to receive a sweepstakes prize or withhold taxes. For submitting tax documentation, we may process your personal data, including, but not limited to, your full name, country of citizenship, permanent residence address, mailing address, date of birth, U.S. taxpayer identification number, or foreign tax identifying number. The Directive (EU) 2021/514 (DAC7) requires us as a digital platform operator to collect, verify, and report data and information on reportable sellers (i.e., practitioners to whom DAC7 applies) conducting relevant activities through the Munay Platform. To comply with our reporting obligations under DAC7, we may process your first name, last name, primary address, date of birth, tax identification number (TIN), V AT number, and financial account identifier (e.g., bank account).

Information Required for Marketing and Promotion: We may collect the practitioner's postal address to promote the Practitioner Services that you provide via the Munay Platform and help you reach more prospective customers looking for Practitioner Services within a certain geographical area.

Purposes we may process the personal data you provided us voluntarily for the purposes defined below. From our perspective, we process your personal data to personalize the use of Munay to the fullest extent possible and to provide you with high-quality Services under the Terms of Service.

Provision of Services: Primarily, we process your personal data to authorize access to our Services and to fulfill our obligations under the Terms of Service for Services provision. Specifically, we use your personal data upon registration to help others (be it a practitioner or a consumer) find your account or profile, schedule, give and/or take services, and track your network of practitioners . In order for you to use the Services, you will need to provide payment (e.g. credit card details) and billing information through our partners – third-party payment providers, which process your personal data encrypted and securely. Please see our Refund and Payment Policy for more information. Please note that without the information provided by you under our Terms of Service, we will be unable to provide you with the functionality of Munay Platform, connect you with other users, allow you to communicate with them and take/give services.

Payment Services: We use third-party payment providers to bill you through an online account payment in lieu of directly processing your credit/debit card information. Your paid balance for one or more services is safe in your account as we use an integrated iframe for checkouts from our partners-payment providers (Stripe and Wise) and practitioners get the payment for each confirmed service securely through third-party payment providers (Stripe and Wise). Correspondingly all transactions are secured as our partners-payment providers use SSL encryption protection. We do not store your payment information on our servers.

Communications: We may contact you via email and other ways, including through publicly available notices, for Services-related purposes (welcome letter, security and legal notices, announcements, Munay updates, reminders, suggestions, etc.). We may also use your data to enable you to communicate with other users through Munay, including exchanging messages, make tribe connections, conducting video calls, and/or leaving feedback about other users. You may also receive certain push notifications via Munay mobile device application when it becomes available. You are able to adjust such notifications using the internal settings of your smartphone. Having received the communications from us, you are always able to opt out of such communications in each message, excluding legal notices, essential reminders/notifications or changes of user settings on Munay.

User Research: Your contact data (including email, phone number and etc.) may also be used for gathering feedback. We may contact you to participate in research to improve the user experience of our product. The research will be used for internal purposes only, including: Feature development and product updates; Marketing activities, including publishing them on Munay on other information resources; Customer Support updates; Other service updates for improving your experience.

Marketing and Promotion of Munay: We may process your first name, last name and email on our mailing list or for the newsletter and send you messages with some commercial or promotional information about our Services. You may always opt out of our marketing messages using the mechanisms described under the respective link in each message and through the user settings available on Munay. If you provide us with your phone number, we may also contact you with some commercial or promotional information about our Services. To promote the Munay Platform through the blog and influencer channels, we allow individuals to participate in the affiliate program on our Website for which we use third party systems such as Referral Rock. When we receive the information to participate in the affiliate program, we process this information to register you as an affiliate and further track the progress of the promotion of the Munay Platform. We may use the postal address collected from you upon your consent in connection with search engine marketing and optimization. Also, please pay attention that we may use the information provided by you as feedback.

Behavioral and Social Media Marketing: We may share your email address with Google and Meta for the purpose of delivering personalized advertisements to you and engaging in behavioral and social media marketing. We will conduct these marketing activities based on our legitimate interest and with consideration for your interests and privacy. Identifying Influencers for Potential Collaborations: We may use third-party services, such as Captiv8, Inc. and LiveRamp Holdings, Inc. to analyze the information you provide to us at the time of registration (such as your name and other identifiers), execute a matching exercise, and discover our most influential customers for the purposes of proposing collaboration with us. In doing so, we may receive some of your personal data from Captiv8, Inc. (such as your social media profiles) and form a joint controllership over your data. In case we discover that you are an influencer and decide to propose collaboration, we will provide you with a short privacy notice explaining this processing activity in detail.

Analytics and Development: In order to establish new ways to improve the Munay Platform, find the points of interest in our Services and for the purposes of analytics, we monitor and analyze the personal data you provide us with, including information you provide upon registration, the web traffic, cookies and usage data, such as the parts of our Services you visit, the date and duration of your visit, your location, type of the device you used during your visit and other relevant data on the use of the Munay Platform. For these purposes, we use services such as Google Analytics, the use of which ensures compliance with our privacy commitments. For the purposes indicated above, we may also run occasional research activities, including personalized “A/B” tests. During the tests, we will display different content to the users based on various criteria, such as their country. The purpose of such tests is to understand user engagement and satisfaction with certain features in order to improve the user experience, develop new useful features, and streamline our Services. We may also carry out polls and surveys through Munay using external GDPR-compliant services. You are not obliged to respond to them and you may opt out of such polls and surveys through user settings. In order to inform, optimize and serve you relevant advertising based on your past use of our Services, we may process your usage data and cookies.

Practitioner Verification and Program Preparation: To ensure a high quality of services given by practitioners on Munay, we may collect and process practitioner credentials to verify their eligibility to provide services claimed by them. Besides that, we cooperate with the practitioners and use their information to help them develop learning programs. In order to verify practitioner identity and identify fraud, we process practitioners’ biometric information and ID. For the purposes of analytics, we additionally process practitioners’ registration data to automate and improve the practitioner verification process.

Improvement of Practitioners’ Ranking Algorithm: We gather and use various metric-based data to enhance the practitioners’ ranking algorithm and improve your experience on the basis of our legitimate interest. This data may also consist of personal data that the practitioners and customers provide on the Munay Platform. Support and Platform Supervision: In case of any disputes on Munay and other Services-connected issues, we may use data (including communications) to resolve such matters, supervise user behavior on the Munay Platform, and respond to any complaints or requests.

Events and Webinars Conducted by Munay: We use the personal data we collect from you when you register and/or attend any of our events or webinars to provide you with access to such events or webinars, as well as to send you registration confirmation, reminders, associated useful materials or the information you have requested about our Services.

Compliance with Legal Requirements: We process certain payment information to comply with applicable legal requirements in the field of finances and/or accounting. We also may process the data collected on the Munay Platform in connection with legal requests we receive from you or any other competent person and/or body, and we may use this information to exercise, defend and/or establish our legal rights.

Fraud Prevention: Certain information, such as your log information, payment information and your behavior on the Munay Platform are subject to our supervision to prevent fraudulent activities and assist you in managing your user sessions.

Changes: We may change the Munay Privacy Policy from time to time. Upon any changes to this Policy, your rights may not be reduced unless you provide explicit consent. The latest version is posted on this page. If we make substantial changes, we will notify you by sending an email.

How Is Personal Data Shared?

In order to provide high-quality services, Munay hires people, enters into agreements with independent contractors as well as cooperates with other services providers, companies and organizations strictly under data processing agreements (DPA) or Standard Contractual Clauses (SCCs). For those reasons, some of your personal data can be passed to the persons mentioned. Munay uses only secure places of storage, such as those provided by Sharetribe, Google Heroku, Amazon Web Services and Squarespaces.

Use of Social Network Platforms: We may use social network platforms like Facebook, Instagram, LinkedIn, YouTube and TikTok to maintain Munay’s social media pages. Please note that LinkedIn acts both as a processor engaged by Munay and as an independent controller of your personal data. Additionally, TikTok and Munay independently process your personal data as independent controllers. As for Munay’s Facebook and Instagram pages, Meta Platforms, Inc. (“Meta”) is a joint controller for the processing of personal data. In particular, Meta and Munay are joint controllers for the pages’ insight data and statistics, your reactions and comments under our posts, and other information you make available to Munay upon contacting us. You may find more information on the Meta joint controllership arrangement at the following link: https://www.facebook.com/legal/terms/page_controller_addendum. You may contact us with any questions related to your activity on Munay’s social media pages on the above-mentioned social network platforms or our processing of your personal data. Munay may have contractors and subsidiaries in other countries, including those outside the European Economic Area, who may have access to your personal data. At the same time, in the cases when we pass your personal data to other persons, we ensure that your personal data is being protected and used only within the purposes specified in this Privacy Policy. This is achieved by using only certified services and products, signing data processing agreements for the protection of personal data with contractors and partners (including the Standard Contractual Clauses adopted by the European Commission and compliant with the EU data protection laws), as well as taking technical measures to ensure the information is protected when stored, used and while being processed and transferred.

Data Transfer in Case of Change of Control or Asset Disposition: In the event of any merger, acquisition, sale or change of control, we’ll continue to ensure the confidentiality of your personal data and give affected users notice before personal data is transferred or becomes subject to a different privacy policy.

Munay Independent Contractors: We work with independent contractors who help us provide you with our Services. Specifically, we may engage such contractors to assist us with data analytics and software development, customer support, promotion, marketing, user research, as well as financial and legal matters. These contractors will only have access to your personal data on the need-to-know basis and under strict privacy and security obligations.

Other Users of the Munay Platform: Your personal data may also be made visible to visitors and users of the Munay Platform. This can happen via personal contacts (between customer and practitioner), or in connection with the social features of the Munay Platform. For example, your profile picture and name may be visible if you have signed up for a group class or if you left a practitioner review.

How Long Will the Personal Data Be Processed and Stored by Munay?

Your personal data will be stored by Munay for no longer than necessary for the purposes for which the personal data is processed. Generally, Munay retains your personal data as long as your account is active. If your last activity on Munay was more than 2 years ago, your account may be considered expired. In this case or when you decide to delete your Munay account, we undertake to remove your personal data from our active systems and servers within 90 days or earlier. Munay stores your personal data processed by AI-powered tools for AI data training purposes for 2 years in the EU and longer for non-EU jurisdictions. However, in case of conflict situations in progress, Munay may retain your personal data for longer in order to be able to establish, exercise or defend legal claims. Upon the settlement of the conflict situation, all personal data gets deleted if the standard retention period has expired. We may also retain some of your personal data for longer if we need it to comply with the applicable legal, regulatory, tax, accounting or other requirements. Personal Data collected when you registered on our mailing list or for the newsletter will be stored as long as you are interested in receiving our emails. We consider that you’re interested in this until you unsubscribe from the mailing list or the newsletter by clicking the respective link contained in each of our emails. After the expiration of the retention period, Munay shall terminate the processing of your personal data unless otherwise set by the relevant legislation.

Your Rights as Data Subject Regarding Your Personal Data Munay Processes Right of Confirmation:

You can obtain confirmation from Munay as to whether personal data concerning you is being processed.

Right of Access: You can access your personal data processed by Munay.

Right to Rectification: You can ask Munay to have incomplete personal data requiring corrections completed.

Right to Erasure (Right to Be Forgotten). You can request Munay to erase personal data.

In most cases, Munay will erase it unless otherwise required by legislation. To delete your personal data, you can: Contact us by email at care@munay.live. We will respond to your request to delete your information within 30 days and notify you of the outcome.

Other Privacy Commitments Cross-border Transfers:

We process your personal data both within the United States and outside the United States. Although countries where we process data may have different laws, we take measures to ensure high standards of data privacy and compliance to our best ability.

Time for Reply and Reaction: Munay will provide information on action taken on your request related to your rights specified above within one month of receipt of the request for the longest. That period may be extended by two further months if Munay is overwhelmed by the number of requests or the request at issue is complicated and requires a lot of action. Munay will inform you of any such extension within one month of receipt of the request, together with the reasons for such delay.

Accessing Account to Provide Support: In exceptional circumstances, such as required customer support, our support specialists may need to access your account. When such an occasion occurs, they will be able to see the personal data submitted to your account, including your scheduled personal events, if your Google, Microsoft Outlook, Apple Calendars and Munay Calendar are connected. We undertake to always ask for your permission to access your account before we start troubleshooting. Prior to granting us your permission, you might also consider editing your privacy settings with Google, Microsoft Outlook, Apple Calendars Help Center to hide your personal events from us. Please note that if you do not want to grant your permission to access your account, it may affect the time and quality of the provision of customer support.

Children’s Privacy: The privacy of children is one of our concerns. Munay Services are not intended for use by children under the age of 18 without the supervision of their parent or legal guardian. If you are under the age of 18 but not less than the age of 13, you will need to ask your parent/legal guardian to set up an account on the Munay Platform that you may use under their supervision. We do not knowingly collect information from children under the age of 13 and discourage the use of Munay Services by children under this age. We encourage parents and legal guardians to monitor their children’s Internet usage and help enforce our Privacy Policy by instructing their children never to provide information on the Munay Platform without their Permission.

Breach Notifications: If there is a personal data breach that is likely to result in a high risk of adversely affecting your rights as the data subject, we would inform you and the respective data protection agencies as to the accidents without undue delay. We would also do our best to minimize any such risks. “DoNotTrack”

Requests: Munay does not share personal data with third parties for their direct marketing purposes. Also, our Services do not support “Do Not Track” requests. California Privacy Rights: In case you are a resident of California, you are entitled to certain rights over your personal data under the California Consumer Privacy Act of 2018. Specifically, as a resident of California, you have the right to: know about the categories and specific pieces of personal data that we have collected about you and access a copy of your personal data (“Right to Know”); have inaccurate personal data about you corrected (“Right to Correction”); request deletion of your personal data that we have collected (“Right to Deletion”); opt out of the sale of your personal data (“Right to Opt-Out”).

Please note that we may ask you and/or your agent to provide certain information to verify your and/or your agent’s identity and authorization before fulfilling the request. The information we request will depend on your prior interactions with us. Munay undertakes to treat you like everyone else and not discriminate against you if you choose to exercise your rights. To submit the request to exercise your rights, please send an email to legal@Munay.live.

Automated Decision-Making and Profiling

As a part of the Munay Platform functionality, we process the personal data of our practitioners and customers in a way that might be considered profiling. Specifically, we use machine-learning algorithms that analyze various metric-based data and determine the practitioner's ranking on the Munay Platform and their visibility to customers. This is done to increase the matching efficiency between customers and practitioners on the Munay Platform and allow practitioners to connect with the optimal number of customers who best fit their way of working. Please note that this type of processing is necessary to provide our Services. To know more about this process and the logic involved, please refer to our Terms of Service. If you want to request human intervention, express your point of view, or contest the decisions made by the algorithms, please send us an email to legal@Munay.live.

Sale of Personal Data

We do not sell your personal data.

Disclosure of Personal Information to Law Enforcement Officials

Munay, Inc. may disclose your personal information to the extent required by law or if we have a good-faith belief that we need to disclose it in order to comply with official investigations or legal proceedings (whether initiated by government or law enforcement officials or private parties, including to meet national security or law enforcement requirements).

Munay considers your use of the Services to be private. However, we may disclose your personal data stored in our databases in order to: (1) comply with the law or legal process served on us; (2) enforce and investigate potential violations of this Privacy Policy; including the use of the Services to participate in or facilitate activities that violate the law; (3) investigate potential fraudulent activities; or (4) protect the rights, property, or safety of Munay, its employees, customers or the public. We hope this Privacy Policy helps you understand how your personal data will be dealt with here at Munay. We will take care of your personal data, so you can use our Services and not be concerned about your privacy. Should you have any questions, e-mail us at care@munay.live.

Your Munay Team