Last updated: May 17, 20232

We – “Vārdu vārti” LLC.– care about the privacy of your data! Your information is used by us only to provide and improve our Services.

General provisions

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of your information when You use our Site – www.oratastic.eu (Oratastic) – and Services on it.

These provisions explain your privacy rights and how the law protects you.

By using our Services, you agree to the collection and use of information in accordance with this Privacy Policy.

Capitalized terms used in this Policy and not otherwise defined shall have the meanings provided for those terms in the Terms of Service.

Our business model

“Vārdu vārti” LLC offers Services – introductory free services and paid educational services. We encourage the users of our free service to upgrade to our paid services in order to earn the money for the running and development of our Services.

We are not advertising to you the products or services of third parties.

We do not sell your information and will not do this in the future.

Collection and use of information about you

There are two main kinds of information collected, while you interact with Oratastic’s Site and Services:

• Personal Data – information that could be used to identify you;
• Non-Personal Data – information that cannot be linked back to you.

Information provided during the creation of your account

During the signing up for the use of Services we receive the following Personal Data about you:

• Username and email address, and for Individual Users – also address. The sharing of this information can be stopped by removing the access of “Vārdu vārti” LLC to the account.
• Payment information – only for paying customers. This information is needed in order to enable commercial transactions – payments for our Services.

Automatically collected information

Certain information, mostly Non-Personal data, is collected automatically by Oratastic’s Site. This includes:

• Log data. Like most of the other websites, the servers of Oratastic’s website automatically collect data about any access or use of our Site and Services on it. This information is recorded in log files and may include IP address, browser type and settings, date and time of use, information about browser configuration, language preferences, and cookie data. This is mostly Non-Personal data but part of the data – e.g. IP address – is Personal.
• Usage and device information. Through the use of the third-party service – Google Analytics – we collect the information about the use of Oratastic’s Site and Services on it. It also collects data about devices you use, browsers, operating system, demographical information. This is Non-Personal data that helps us to gain better understanding about the usage of our Service and will help us to optimize our Services and develop new ones.
• Oratastic’s Site uses cookies – small text files stored on your device and used by web browsers to deliver personalized content and remember logins and account settings. This information helps us to provide the Services in your selected scope and time and use our Services in a simpler, more convenient way. This is Non-Personal data.

Use of the obtained information

“Vārdu vārti” LLC uses, processes, and stores your Personal Data and Non-Personal Data in order to perform our contract with you and based on our legitimate interests in order to provide the Services. These interests are the following:

• To display the content that is associated with your account and make sure it is available to you when you use our Services.
• To provide and administer the Site and Services on it: to authenticate users for security purposes, to provide transactions, to research usage for the improvement and further development of our Services.
• To communicate to you about your use of our Site and Services on it, to announce new products and updates. The information is needed to respond to your requests for assistance, including providing account verification support if you’re having difficulty accessing your account.
• To detect and prevent fraud and misuse of our Services through the calculations of aggregate statistics on the number of unique devices that are using the Services on our Site.
• In the future “Vārdu vārti” Ltd. may use the information to send you direct emails with offers of our Services. This marketing information will be sent to you only if you consent to it at the time you create your account or any point thereafter. You will always have an option to unsubscribe.

Sharing and sale of the information

Your Personal Data can be shared by us to third parties only in these cases:

• If we have your explicit consent to share your Personal Data.
• If we need to investigate potential violations of the Terms of Service, to enforce those Terms of Service, or to investigate, prevent, or take action regarding illegal activities, suspected fraud, or potential threats against persons, property, or the systems on which we operate our Site and Services.
• If the law requires the access, preservation, or disclosure of your Personal Data in order to protect the rights, property, or personal safety of “Vārdu vārti” LLC employees and users of our Site and Services, or to respond to lawful requests by public authorities, including national security or law enforcement requests.
• If there is a merger, acquisition, bankruptcy, reorganization, sale of some or all our assets or stock, public offering of securities, or steps in consideration of such activities (e.g., due diligence). In a such situation part or all of your Personal Data may be shared with or transferred to another entity, subject to this Privacy Policy.

Your Non-Personal Data can be shared by us publicly and to third parties, for example, in public reports about the provision of our Services, progress and yearly reports.

“Vārdu vārti” LLC does not share your Personal Data with third parties for the purpose of enabling them to deliver their advertisements to you.

We do not sell or rent your Personal Data.

We do not share your Personal Data to public except for the cases mentioned above.

Permissions to third-party applications and plugins

Some third-party applications and services that work with us may ask for permission to access your Information. Those applications will notice you and request your consent in order to obtain such access or information. Please consider your selection of your permissions carefully.

Some third parties’ embedded content or plugins on our Site, such as Facebook “Like” buttons, may allow their operators to learn that you have visited the Site, and they may combine this knowledge with other data they have collected about your visits to other websites or online services that can identify you.

Data collected by third parties through these applications and plugins is subject to each parties’ own policies. We encourage you to read those policies and understand how other companies use your data.

Information about children

We do not knowingly collect personal information from children under the age of 13.

Please, do not submit any personal information to us if you are under the age of 13. If we will find out that we have collected personal information from a child younger than 13 years of age, we will take reasonable measures to remove that information from our systems.

If in your country the age of digital consent is older than 13, you must be at least that age to use the Site and its Services.

Storage, transfer, retention, and deletion of data

The information submitted to us will be stored and processed in Latvia. If you post or transfer any information to or through our Site and its Services, you are agreeing that it is hosted and accessed in Latvia. Please note that the laws of Latvia may be different from the privacy laws applicable to the place where you are resident.

Security of your information

“Vārdu vārti” LLC takes reasonable precautions to protect the security of your Information.

Nevertheless, transmissions through the internet cannot be guaranteed to be 100% secure. Thus, we cannot ensure the security of Information you transmit to us, including your Personal Data. Accordingly, you acknowledge that you provide this information at your own risk. We recommend that you take the appropriate steps to secure all computing devices that you use in connection with our Site, Software, and/or Services.

If “Vārdu vārti” LLC discovers a case of a security system breach, we may attempt to notify you through the e-mail address that you have provided to us as well as posting a notice on the Site.

Deletion of Personal Data

You can remove your Personal Data from Oratastic at any time by logging into your account, accessing the Settings page, and then deleting your account.

For the financial security reasons, subscribers of our paid services will first be instructed to cancel their subscriptions before they can delete their Oratastic account.

Some of your Personal Data may be kept by us for our legitimate business interests, including fraud detection and prevention and to comply with our legal obligations including tax, legal reporting, and auditing obligations. This data will be retained as long as it will be reasonably necessary.

Closure of your Oratastic account

There may be cases when your Oratastic account is closed by “Vārdu vārti” LLC due to your violation of the Terms of Service.

In such case you may contact “Vārdu vārti” LLC and request the deletion of your data. Oratastic will evaluate such requests on a case by case basis, pursuant to our legal obligations.

Changes of Privacy Policy

This Policy will be updated in the future due to the development of Oratastic and legal changes.

Nevertheless, we in “Vārdu vārti” LLC will maintain our commitment to respect your privacy. We will inform you about any changes that may leave impact on your rights under this Policy. Hereby you are advise to check on this page with the Privacy Policy to review any potential changes.

Your use of Oratastic after any changes means that you agree with the new Privacy Policy.

In a case of your disagreement with any changes in this Privacy Policy you will need to delete your Oratastic account.

Regional provisions

Users from European Economic Area, Switzerland, and the United Kingdom

If you are a user located in the European Economic Area (EEA), Switzerland, or the United Kingdom (UK), you can:

• Request a Personal Data report by submitting a request to us. This report will include the Personal Data we have about you, provided to you in a structured, commonly used, and portable format. You must have the Oratastic account to submit this request. Please note that “Vārdu vārti” LLC may request additional information from you to verify your identity before we disclose any information.
• Have your Personal Data corrected or deleted. Some Personal Data can be updated by you: You can update your name and email address through your Oratastic account settings. If you have problems updating this information, please submit a request to us.
• Ask us to stop processing your Personal Data, including when we use your Personal Data to send you marketing emails. We only send marketing communications to users located in the EEA, Switzerland, and the UK with your prior consent, and you may withdraw your consent at any time by clicking the “unsubscribe” link found within Oratastic emails and changing your contact preferences. Please note that you will continue to receive transactional messages related to our Services, even if you unsubscribe from marketing emails.
• Complain to a regulator. If you’re based in the EEA, Switzerland, or the UK and think that we have not complied with data protection laws, you have a right to lodge a complaint with your local supervisory authority.

If “Vārdu vārti” LLC transfers the personal data of EEA, Swiss, and UK residents outside of those regions it does so via appropriate safeguards of user privacy, such as standard contractual clauses.

Users from Brazil

This part of the Privacy Policy applies to residents of Brazil in accordance with the Brazilian General Data Protection Law. According to the provisions of this law you have a right to request from us the following:

• To confirm whether we process your data.
• To provide access to and/or a copy of certain information we hold about you.
• To correct incomplete, inaccurate, and outdated data.
• To anonymize, block, or delete data that is unnecessary, excessive, or not being processed in accordance with Brazilian General Data Protection Law.
• To port your personal data to another service or product vendor.
• To delete personal data processed with your consent, when applicable
• To provide you with information regarding the public and private entities with which we share data.
• To provide you with information about the possibility of withdrawing consent and the consequences of such withdrawal, where applicable.
• To withdraw your consent.

Part of these rights can be exercised by you through your Oratastic account page. Thus, you can correct your Personal Data or delete your Personal Data by deleting your account. You can also submit requests to us. We will require you to verify your identity before fulfilling of your request.

Users from California, United States

This part of the Privacy Policy applies to California residents only.

Categories of the collected information

California Consumer Privacy Act (“CCPA”) obliges us to provide you with additional information on the collection, use, and disclosure of your “personal information” (as defined in this legal act).

In addition to other clauses in this Privacy Policy, we are required to inform California residents about the “categories” of personal information that we collect and disclose for business purposes (as defined by applicable law). This includes the following categories:

• identifiers (name, email address, social network account and profile data).
• commercial information (e.g. transaction data for a paid account).
• financial data (e.g. payment method, financial account information).
• internet or other network or device activity (e.g. IP address, information about the usage).
• location information (e.g., the general location where you use your device when interacting with the Site and/or Services).
• sensory information (e.g. audio recordings of your calls to us).
• inference data about you.
• any other information that identifies or can be reasonably associated with you.

We collect these categories of personal information from different sources, as described in the section titled, “Collection and use of information about you” above. These categories of personal information are used by us for the purposes defined in the section “Use of the obtained information”.

Your rights

According to the provisions of CCPA residents of California have a right to request from us the following:

• To provide the access to and/or a copy of certain information we hold about you.
• To provide you a summary of the categories of personal information we have collected or disclosed about you over the last 12 months including the categories of the information sources, the purpose for collecting of your personal information as well as the third parties with whom we shared personal information.
• To delete certain information we have about you.

If we offer any financial incentives, you have the right to receive information about them.

You have the right not to be discriminated for exercising your rights.

Certain types of information are needed so that we can provide the Site and Services to you. In such case, before the deletion of such data you will receive explanation from us and you will be required to provide explicit agreement to the data deletion.

You can exercise the above mentioned rights in the following ways:

• Request a personal data report or any other related information from us through the e-mail info@oratastic.eu.
• Delete your personal information from Oratastic by deleting your account. You must be signed into your Oratastic account to submit this request, and you will be required to provide your password to confirm that you want to delete your account.

In order to satisfy your requests we will need sufficient information from you to verify your identity.

It is possible for you to designate an authorized agent to make a request on your behalf but in this case we will need written authorization from you about the agent who acts on your behalf. Also in this case we will need direct verification of your identity.

“Vārdu vārti” LLC. does not sell any personal information that is received through our services, including Oratastic.

We do share some information as described in the “Sharing and sale of the information” section above, and we allow third parties to collect certain information about your activity, for example through cookies. You can control these cookies through browser settings and other controls.

“Shine the Light” law

If you are a California resident, you can ask for a list of possible third parties that have received your information for their direct marketing purposes during the previous calendar year. This list also contains the types of information shared.

We provide such a list for free. Your requests should be sent to our e-mail: info@oratastic.eu.

Users from Nevada, United States

If you are a Nevada resident, according to the provisions of Nevada Privacy of Information Collected on the Internet from Consumers Act you may opt of the sale of “personally identifiable information” for monetary consideration to a person for that person to license or sell such information to additional persons.

Such “personally identifiable information” includes first and last name, address, email address, phone number or an identifier that allows a specific person to be contacted either physically or online.

“Vārdu vārti” LLC does not engage in such activities.

However, if you are a Nevada resident who has purchased services from us, you may submit a request to opt out of any potential future sales under Nevada law by sending us an e-mail to info@oratastic.eu. We will require you to verify your identity before fulfilling your request in a case if our practices will change and we will start sale of your information.

Our contacts

You are invited to contact us in a case of any questions regarding this Privacy Policy by contacting us at info@oratastic.eu

For the purposes of this Policy, when we say “Vārdu vārti” LLC, “Oratastic”, “we,” or “us,” we mean “Vārdu vārti” LLC located in the following address:

Avotu iela 33, Rīga, LV-1009, Latvia.