Last updated and effective: 2/11/2025
MeTabi, Inc. (“MeTabi,” “us,” “we,” or “our”) owns and operates the Mira line of virtual assistants and language learning programs providing communications, tutoring supports, and language learning for individuals who want to learn another language and for individuals for whom English is not their first language (each referred to as a “Service,” and collectively as the “Services”).
In this Privacy Policy, we refer to users of the Services as “you” or “your. ” When we refer to “Personal Information,” we mean information that identifies, describes, or relates to an identified or identifiable individual, or that is reasonably capable of being associated with or could reasonably be linked, directly or indirectly, with a particular individual or household.
This Privacy Policy describes how we may collect, use, and disclose Personal Information that we collect from individuals who use the Services, as well as your rights regarding your Personal Information. Our privacy practices may be further governed by a contract between us and our customer (the “Customer”).
Personal Information We Collect
The Personal Information we collect and how we may use it depends in large part on the intended audience for a particular Service as described in the chart below. For all products, when you choose to engage with the Services, you will use your device microphone to ask a question or to respond to a prompt. In some cases, we transcribe the audio and use it to respond to your question. For our coaching and tutoring Services, we also use the audio as part of the language assessment.
| Services Intended for Use by Parents | ||
| Services | Personal Information We Collect | Purpose for Collecting this Personal Information |
| Mira Assistant | Recorded audioTranscribed audioLanguage choiceConsent to engage with the MIRA Assistant chatbot | We collect the recorded audio to provide a response to the parent’s question;We transcribe the audio to create aggregate reports to the customer about the types of questions being asked: Language is used to deliver the Service in the appropriate language; We maintain a record of consent to use the MIRA Assistant chatbot. |
| Mira Newcomer Parent | In addition to the data elements listed above, we also collect:Parent email addressPassword | In addition to what is listed above, we collect the parent’s email address and password to allow the parent to log in. |
| Services Intended for Use by Adult Students | ||
| Mira Career | Email addressPasswordFirst and last nameRecorded audio of conversation with the MIRA coachTranscript of the audioAssessment data associated with various activities within the Service | We collect the email address and password to allow the user to log in; We collect the first and last name to personalize the Service and provide reporting to the Customer about users of the Services;We collect the recorded audio, transcript, and assessment data associated with various activities within the Services to provide the core assessment functionality of the Service. |
| Services Intended for Use by K12 and University Students | ||
| Mira Coach+ | Student email addressPasswordFirst and last nameAudio conversation with the Mira coachTranscript of the audio;Assessment data associated with various activities within the Service | We collect the email address and password to allow the user to log in; We collect the first and last name to personalize the Service and provide reporting to the Customer about users of the Services;We collect the recorded audio, transcript, and assessment data associated with various activities within the Services to provide the core language assessment functionality of the Service. |
As you use the Services, we also automatically collect certain information from you using various tracking technologies. The information we collect includes the Internet Protocol (IP) address associated with your device, your browser type and version, machine make and model, the operating system of your device, and other device-specific information, as well the time that you access the Services, the amount of time you spend using the Services, the pages within the Services you visit, geolocation, and the referral URL, and related activity and log files.
We use this information to help us understand how the Services are used, diagnose technical problems, remember your preferences, and for security purposes (such as preventing fraud and abuse and protecting our computer, software, hardware, and communications systems). When this information is in a form that identifies you as an individual, we treat it as Personal Information in accordance with this Privacy Policy.
Children’s Privacy
Only our Mira Coach+ Services are intended for use by students attending education institutions. In the event that an education institution Customer chooses to use our Services with students under the age of 13 or otherwise under the age of consent for privacy purposes in their jurisdiction, the education institution Customer is solely responsible for obtaining any necessary parental consents or providing consent in lieu of the parents, in accordance with applicable law, for the students’ use of Mira Coach+ and our collection and use of the students data. If we learn that we have inadvertently collected such Personal Information without the required consent, we will take steps to promptly delete it. Data of students under the age of 13 will otherwise be protected, used, and disclosed in the same manner as all other data under this Privacy Policy
Parents of children who are using the Services under the direction of an education institution Customer should contact the Customer if they wish to review or request deletion of their child’s Personal Information, or request that we make no further contact with their child. We will work with the Customer as necessary to facilitate that or any related rights requests.
For more information about our collection and use of Personal Information from children, please see our Children’s Privacy Notice.
How and Why we Use Your Personal Information
We do not sell or rent your Personal Information, and we do not use your Personal Information for advertising purposes.
Generally, we use your Personal Information as described above, including:
- For any use or disclosure to which you have expressly consented, including through a contract with us;
- To provide and maintain the Services, including to create accounts where applicable, provide speech-to-text and translation of questions, to provide responses to questions, and to provide the language assessment functionality of certain Services.
- To provide reports to the Customer on use of the Services and student language assessments;
- To provide support, including via phone and email, to help maintain the security of the Services, and to communicate with you regarding the Services and solicit parent and adult student feedback on the Services.
- In the event of a reorganization, merger, sale, assignment, bankruptcy, or similar business change, in which case we may need to transfer your Personal Information to a parent company, re-organized entity, or new owner after the sale or reorganization for them to use in accordance with this Privacy Policy.
- In the event of an investigation, during which we may share your Personal Information with entities assisting us, or as may be required by applicable law in response to a known or suspected violation of our terms of use, fraud prevention, or other unlawful use of the Services.
- We may use and disclose your Personal Information as necessary to protect our rights or the rights and safety of our users; as necessary in the event of a court order, regulatory inquiry, or other lawful request; or otherwise as required by law. Provided, however, that unless legally prohibited, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime.
- To provide existing Education Customers with marketing materials, including updates and offers about the Services. At any time, you may unsubscribe or opt-out of further email communications by clicking on the link labeled “unsubscribe” or “manage preferences” available at the bottom of each email or by contacting us at legal@metabi.com.
Where We Share Your Personal Information
To assist us in delivering and maintaining Services, including to provide certain features such as data hosting, speech-to-text, and transcription, it is sometimes necessary to share your Personal Information with third-party providers. The list of third party subprocessors that we may use, which we may update from time to time in our sole discretion, is available here,
Network Operators
Use of our Services may involve the use of third-party search engine or Internet operators or telecommunications carriers. These operators are not our subprocessors or contractors, and any information these operators collect in connection with your use of the Services is not subject to this Privacy Policy. We are not responsible for the acts or omissions of these operators.
Aggregated Information
To the extent permitted by applicable law, we may aggregate or deidentify any of your Personal Information so that it may no longer contain identifiers that can reasonably be used to link it to you, and use or disclose the resulting aggregated or deidentified data for any legal purpose.
Security
We use physical, administrative, and technical safeguards to help protect the confidentiality, security, and integrity of your Personal Information. However, the Internet is not perfectly secure, and we are not responsible for security breaches not reasonably foreseeable or reasonably within our control.
How Long We Retain Your Personal Information
We are generally not under any obligation to retain your Personal Information for a specified period of time, and we may destroy or delete your Personal Information at any time if we do not have a business or legal use for it, as described within this Privacy Policy.
We retain voice audio for as long as is necessary to provide the Services. This might mean, for example, that we retain voice audio for the duration of the chat session. Once that data has been transcribed, we delete the voice audio.
We delete transcripts of the chats and other Personal Information within 90 days after termination of a contract or within 30 days of a written request from the Customer. During a contract term, we delete transcripts on an annual cycle.
We may create and retain deidentified data, including deidentified transcripts, for use for lawfully permissible purposes.
Opt-Out Policy
We may send our Customers emails with information about the Services that we believe may be of interest. You may opt out of receiving these emails by clicking on the “unsubscribe” or “manage preferences” link that appears on the bottom of each email we send, or by contacting us at legal@metabi.com. Note that even if you have opted out of marketing emails, we may still send you service-related emails.
ADDITIONAL INFORMATION FOR USERS FROM THE EUROPEAN ECONOMIC AREA (EEA), SWITZERLAND, AND THE UNITED KINGDOM (UK)
When you are accessing the Services that we make available in the EEA, Switzerland, and the UK under a Customer account, we function as a “data processor” under the General Data Protection Regulation (“GDPR”). By visiting or using our Services, you acknowledge that we may transfer, process and store your Personal Information in the United States. Wherever the Personal Information is, it will be treated in accordance with this Privacy Policy and applicable privacy laws of the United States. These laws may be different from the privacy laws in your country. However, this does not change our commitment to safeguard your privacy, and we will comply with all applicable laws relating to the cross-border disclosure of your Personal Information.
Where required, we will implement Standard Contractual Clauses with our third parties or rely on such other transfer mechanisms to ensure that the transfer of your Personal Information outside of your country is lawful. You may request details of the transfer mechanisms that we rely on to transfer personal information outside of your country by emailing us at legal@metabi.com.
Your Rights
Depending on where you are located or where you reside, applicable laws may provide you with rights regarding your Personal Information, and we will respect those rights as required by law.
If you are located in the EEA, Switzerland, or the UK, you have the right to:
- Access, update, or correct your Personal Information
- Request deletion of your Personal Information
- Object to certain processing of your Personal Information, including processing related to marketing;
- Receive a machine-readable copy of Personal Information concerning you that you have provided to us:
- In certain circumstances, request to transfer your Personal Information to an applicable third party
- Where you have provided your consent for our processing of your Personal Information, you may withdraw such consent by contacting us using the details provided below in the “Contact Us” section.
- You may also restrict how we use your Personal Information while a complaint is being investigated.
The rules in your country may provide you with additional rights or may limit these rights. In all cases, we will provide rights in compliance with applicable laws, and if you contact us to exercise any of these rights, we will verify your request and respond within the time period required by applicable law. Please be aware, however, that your exercise of these rights is subject to certain exemptions to safeguard the public interest (for example, prevention or detection of crime) and our interests (for example, our maintenance of legal privilege).
If you would like to exercise your rights as described above, please contact the Customer. We will work with them in accordance with our applicable legal obligations to help facilitate their response to your request.
Updates to This Privacy Policy
As our business continues to evolve, we may make changes to this Privacy Policy. We will alert you to changes by providing notice within the Services or otherwise as required by law. If we make material changes to this Privacy Policy, we will send notice and request consent from the Customer in the manner required by law. The “last updated” note at the top of this policy indicates when it was last revised.
Contact
To exercise your rights under this Privacy Policy, learn more about your rights or our privacy practices, or to request access to this Privacy Policy in an alternative format, contact us at:
Mail:
940 Willamette St. Suite 530
Eugene, OR 97401
E-mail: legal@metabi.com