1. Introduction

LinguaStep (“we”, “us”, “our”) is committed to protecting your privacy and handling your personal data in a transparent and secure manner.

This Privacy Policy explains how we collect, use, store, and protect personal information when you access or use our website and services. It applies to users located in Australia, the European Union (EU), the United Kingdom (UK), and Canada, and is designed to comply with applicable privacy laws, including:

• Australian Privacy Act 1988 
• EU General Data Protection Regulation (GDPR) 
• UK GDPR & Data Protection Act 2018 
• Canadian Personal Information Protection and Electronic Documents Act (PIPEDA) 

2. Company Details (Data Controller)

Trigo Xo Pty LTD

Company No: 692522071

Address: 4 Innes Parkway, Lakelands, WA 6180, Australia

Phone: +61 478 745 200

Email: [email protected]

For the purposes of applicable data protection laws, Trigo Xo Pty LTD acts as the Data Controller.

3. Information We Collect

We may collect the following categories of personal data:

1. a) Information You Provide

• Full name 
• Email address 
• Billing and payment details 
• Account login information 
• Course enrollment details 
• Communications with our support team 

1. b) Automatically Collected Information

• IP address 
• Browser type and device information 
• Pages visited and usage data 
• Cookies and similar tracking technologies 

1. c) Payment Information

Payments are processed securely by third-party payment providers. We do not store full credit card details on our servers.

4. How We Use Your Information

We use your personal data to:

• Provide access to online courses and services 
• Process payments and refunds 
• Communicate with you regarding your account or purchases 
• Provide customer support 
• Improve website functionality and user experience 
• Send service-related or marketing emails (where consent is given) 
• Comply with legal and regulatory obligations 

5. Legal Bases for Processing (EU & UK Users)

Under GDPR, we process personal data based on the following legal grounds:

• Performance of a contract 
• User consent 
• Legal obligation 
• Legitimate business interests (without overriding user rights) 

6. Sharing of Information

We may share personal data only with trusted third parties, including:

• Payment processors 
• Email and CRM platforms 
• Hosting and analytics providers 
• Regulatory or legal authorities when required by law 

All third parties are required to protect your data and use it only for authorized purposes.

7. International Data Transfers

Your information may be stored or processed outside your country of residence, including in Australia, the EU, the UK, or other jurisdictions.

Where international transfers occur, we ensure appropriate safeguards are in place, such as standard contractual clauses or equivalent legal protections.

8. Data Retention

We retain personal data only for as long as necessary to:

• Provide our services 
• Meet legal, tax, and accounting requirements 
• Resolve disputes and enforce agreements 

9. Your Rights

Depending on your location, you may have the following rights:

EU & UK Users

• Right to access your data 
• Right to rectification 
• Right to erasure (“right to be forgotten”) 
• Right to restrict or object to processing 
• Right to data portability 
• Right to withdraw consent at any time 

Canadian Users

• Right to access personal data 
• Right to request correction of inaccurate information 

Australian Users

• Right to access and correct personal information 
• Right to make a privacy complaint 

To exercise any of these rights, contact us at [email protected].

10. Cookies

We use cookies and similar technologies to enhance website functionality and analyze traffic. You may control or disable cookies through your browser settings.

11. Data Security

We implement appropriate technical and organizational measures to protect personal data against unauthorized access, misuse, loss, or disclosure.

However, no online system is 100% secure, and we cannot guarantee absolute security.

12. Children’s Privacy

Our services are not directed to children under the age of 16. We do not knowingly collect personal data from minors.

13. Changes to This Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated revision date.

14. Contact Us

If you have questions about this Privacy Policy or how we handle your data, please contact:

📧 [email protected]

📞 +61 478 745 200