Scope and Audience

• Applies company‑wide to all SignWow U.S. websites, apps, and programs.
• Covers all user types, including consumers, learners, instructors, contractors, business clients, and website visitors.
• Includes, without limitation, our ASL learning and support services (1:1, group sessions, on‑demand content, community features, assessments, and related tools).

Key Principles

• Transparency and choice: we strive to provide clear notices and meaningful controls.
• Security by design: layered safeguards proportionate to data sensitivity.
• Purpose limitation and minimization: collect only what we need and keep it only as long as necessary.
• No sale or rental of personal information or raw video recordings; no "sharing" for cross‑context behavioral advertising.

Definitions

• "Personal information" means information that identifies or can reasonably be linked to an individual or household.
• "Recordings" means audio/video of sessions, transcripts/captions, chat, and related metadata created during use of the Services.
• "Sell" and "Share" have the meanings under applicable U.S. state privacy laws (e.g., California).

Information We Collect

A) You provide to us

• Account and profile data (e.g., name, email, phone, time zone, preferences).
• Transaction and billing data processed by our payment providers (we do not store full card numbers).
• Content you submit (assignments, posts, feedback, survey responses, support requests).

B) Session content and recordings (if enabled or required for safety/QA)

• Audio/video, transcripts/captions, chat logs, whiteboards/screen shares (if enabled), in‑session reactions, and timestamps.
• Technical and network metadata (device/OS/browser, IP‑derived general location, performance telemetry).

C) Automatically collected data

• Usage and diagnostics (features used, app events, crash logs, page views).
• Cookies/SDKs for authentication, preferences, performance measurement (see "Cookies & Tracking").

D) From others

• Organizations purchasing seats for users (rosters, emails).
• Instructors submitting availability, credentials, and compliance documentation.
• Service providers and integration partners acting on our behalf (e.g., hosting, video processing, analytics).

How We Use Information

We use personal information for the following purposes: (a) to provide and maintain the Services; (b) to authenticate users and secure accounts; (c) to enable scheduling, instruction, and customer support; (d) to record and review sessions for quality assurance, safety, training, and compliance; (e) to conduct research and development, including developing, testing, and improving features, algorithms, and machine‑learning/AI models; (f) to personalize content and measure performance; (g) to process payments and prevent fraud; (h) to comply with law and enforce terms; and (i) with your direction or consent.

• Operate, maintain, and secure the Services; detect/prevent fraud and abuse.
• Provide sessions, scheduling, communications, and customer support.
• Internal research and development: evaluating, training, and improving AI‑powered features; product analytics; quality assurance; curriculum and content development.
• Personalize learning paths and recommendations within the Services.
• Comply with law, enforce our terms, and protect rights, safety, and integrity.

How We Disclose Personal Information

We disclose personal information to: (i) service providers that process data on our behalf under written contracts; (ii) advisors (legal, tax, accounting), auditors, and potential acquirers in corporate transactions; (iii) authorities where required by law; and (iv) with your direction or consent.

"Sale" or "Share."

Certain U.S. state laws define "sell" or "share" broadly to include making personal information available to third parties for valuable consideration or for cross‑context behavioral advertising. We do not publicly disclose session recordings. Where our practices constitute a "sale" or "share," we will provide required notice and a means to opt out (see Section 10) and honor opt‑out preference signals where applicable (see Section 11).

De‑identified and Aggregated Data.

We may create and disclose de‑identified or aggregated datasets derived from recordings and other information for research, analytics, and product improvement. We maintain technical and organizational safeguards designed to prevent re‑identification, and we contractually require recipients not to attempt re‑identification.

Notice at Collection (Summary)

We collect the categories of personal information listed below for the purposes described in this Policy, retain them for the periods stated or as required by law, and may disclose them to the types of recipients identified. Where required by law, you may have rights to access, delete, correct, or opt out of certain processing (including the "sale" or "sharing" of personal information).

Our Position on Selling/Sharing

• We do not sell or rent your personal information or raw video recordings.
• We do not "share" personal information for cross‑context behavioral advertising.
• We may use de‑identified and aggregated information for internal analytics and reporting.

Disclosures to Service Providers/Processors

We disclose personal information to third parties only as described below and under contracts that restrict use to our documented instructions:

• Cloud hosting, content delivery, video processing/transcription, communications, customer support, analytics, payments, and security vendors.
• Professional advisors and auditors under confidentiality obligations.
• Business transfers (e.g., merger or acquisition). We will continue to honor this Policy or provide notice and choices if practices materially change.
• Legal and safety disclosures as required to comply with law or protect rights and safety.

State‑Specific Disclosures

California (CCPA/CPRA): California residents have the rights described in Section 10. Where our practices constitute a "sale" or "share," you may opt out at any time using the "Do Not Sell or Share My Personal Information" link or in‑product settings. We also provide the right to limit use of sensitive personal information where applicable. We honor GPC signals for browser interactions.

Colorado, Connecticut, Virginia, and Utah: Residents of these states may have rights to access, correct, delete, and obtain a copy of personal data, and to opt out of targeted advertising, sale, or certain profiling. Colorado residents may use a universal opt‑out mechanism recognized by the Colorado Attorney General. We will honor such signals as required.

Nevada: Nevada residents may direct us not to sell personal information under NRS 603A by emailing privacy@signwow.com with the subject line "Nevada Do Not Sell Request."

Cookies & Tracking Technologies

• Strictly necessary cookies for login and session continuity.
• Functional/performance cookies for preferences and diagnostics.
• We do not use cookies/SDKs for cross‑context behavioral advertising.
• You can control cookies via your browser/app settings; disabling certain cookies may affect functionality.

Data Retention

We retain personal information only as long as reasonably necessary for the purposes described in this Policy and to comply with legal obligations, resolve disputes, and enforce agreements. By default, session recordings are retained up to 24 months unless you request earlier deletion (subject to safety/legal holds). Transactional/accounting records may be retained longer to meet legal requirements. De‑identified/aggregated data may be retained for a longer period.

Security

We implement administrative, technical, and physical safeguards appropriate to the sensitivity of the information, such as encryption in transit, access controls, audit logging, and vendor risk management. No method of transmission or storage is completely secure. Please use strong credentials and keep them confidential.

Data Breach Notification

If we determine that a security incident has compromised personal information, we will notify affected individuals and appropriate authorities in accordance with applicable law.

Data Deletion & Account Closure

• In‑product: use available settings to request deletion or close your account (where supported).
• By email: contact privacy@signwow.com with the subject "Data Deletion Request" and include the email associated with your account.

Verified requests will be processed within the timelines required by law (e.g., generally within 45 days for certain U.S. state laws, with permitted extensions where necessary).

Your U.S. State Privacy Rights

Residents of certain states (e.g., CA, CO, CT, UT, VA) may have additional rights, which can include:

• Confirming whether we process your personal information and accessing it.
• Correcting inaccuracies and requesting deletion (subject to exceptions).
• Receiving a portable copy of certain information.
• Opting out of targeted advertising, "sale," or profiling for significant decisions (not applicable where we do not sell/share as defined).
• Appealing certain decisions. We will explain how to appeal if we deny a request.

To exercise rights, contact privacy@signwow.com or use in‑product controls. We may need to verify your identity. Authorized agents may submit certain requests on your behalf where permitted by law.

Children & Teens

• Our Services are intended for users 14 years of age and older.
• Users under 18 must have verifiable consent and supervision of a parent/guardian, who is responsible for the minor's use and any payments. The consent form for a parent/guardian to complete this on behalf of their minor can be found by clicking here.
• We do not knowingly collect personal information from children under 13. If we learn that we have done so, we will delete it.

Recordings & Related Data

The following applies specifically to ASL services offered by SignWow (live or recorded lessons, group sessions, workshops, community forums, assessments, and related features):

• Purpose of recordings: operations, safety, quality assurance, internal research and development (including training/evaluating AI features), product improvement, and staff training.
• Notice/consent: where required by law, we provide in‑session notices and/or obtain consent before recording. If recording is disabled upon request, some features may be unavailable.
• Access/deletion: subject to verification and applicable exceptions (e.g., safety/legal holds), you may request access to or deletion of recordings associated with your account.
• No sale or rental: we do not sell or rent raw video recordings or personal information to third parties; we also do not share personal information for cross‑context behavioral advertising.
• Retention: unless otherwise required, recordings are retained up to 24 months by default and then deleted or de‑identified.

All live sessions, practice rooms, and support interactions conducted through the Services are recorded (audio, video, screen where applicable) and may be transcribed. By joining or continuing a session or support interaction, you acknowledge and consent to such recording and use as described in this Policy. If you do not consent to recording, do not use the Services.

Recordings are used for quality assurance, safety and compliance, coaching and calibration of instructors, research and product development (including development, testing, and improvement of machine learning and artificial intelligence models), and customer support. Recordings are not posted publicly and are accessible only to authorized personnel and service providers under contractual confidentiality and security obligations.

Do Not Track

Some browsers offer "Do Not Track" (DNT) signals. Because there is no industry standard governing DNT, we do not respond to DNT signals.

Automated Decision‑Making

We do not make decisions based solely on automated processing, including profiling, that produce legal or similarly significant effects.

International Transfers

We operate in the United States. If you access the Services from outside the U.S. or we transfer information to other countries, we take steps designed to ensure an appropriate level of protection consistent with this Policy.

Governing Law & Dispute Resolution

This Policy and any disputes relating to it are governed by the laws of the State of New York. Any dispute will be resolved in accordance with the dispute resolution terms in our Terms of Use or, if none apply, in the state or federal courts located in New York County, New York.

Changes to This Policy

We may update this Policy from time to time. If we make material changes, we will provide notice (e.g., by email or in‑app) and update the "Effective date" above.

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