PRIVACY POLICY

Last Updated: June 26, 2026

Supplemental Privacy Policy for Busuu

The purpose of this Supplemental Privacy Policy for Busuu ("Supplemental Privacy Policy") is to describe how we at Busuu Limited, including our parent company Chegg, Inc., together with other affiliates and subsidiary companies (collectively, "Chegg") use the personal data that we collect when you use Busuu.

The main Chegg Privacy Policy provides information on how and why your personal data is processed or used to support Chegg services (including Busuu), the legal grounds for the processing, the privacy choices you may exercise under applicable data protection laws, and the contact details for the exercise of such choices. This Supplemental Privacy Policy supplements (but does not replace) the Chegg Privacy Policy by providing additional details on the personal data that we collect, use, and share when you use Busuu.

Where there is an inconsistency or contradiction between this Supplemental Privacy Notice and the Chegg Privacy Notice, this Supplemental Privacy Notice shall prevail in relation to your use of Busuu. Capitalized terms used but not defined in this Supplemental Privacy Policy shall have the meanings given to them in the Chegg Privacy Policy.

This Supplemental Privacy Policy consists of two parts:

• Part One sets out the privacy practices that apply across our Services.

• Part Two sets out the privacy practices specific to Busuu.
  

PART ONE: OUR PRIVACY PRACTICES ACROSS OUR SERVICES

The main Chegg Privacy Policy is available here (including any jurisdiction-specific disclosures incorporated by reference).

PART TWO: SUPPLEMENTAL INFORMATION SPECIFIC TO BUSUU

1. Who We Are

Chegg is the data controller (i.e., the entity that determines the means and purposes of collecting, using, and disclosing personal information) for personal data collected through Busuu.

Controller Contact Details: 5th Floor, Business Cube, 43 Worship Street, London EC2A 2DU, United Kingdom.

Email: privacy@chegg.com

2. Additional Personal Data We Collect

In addition to the information described in the Chegg Privacy Policy under “Our Collection and Use of Personal Data" section, we collect the additional following categories of information when you use Busuu:

- Learning Progress Data, including content consumed and, where applicable, your answers, course progression, proficiency, and other usage information, such as lesson consumption (e.g., lessons, checkpoints, and certificates), Smart Review consumption, fluency score, Smart Review percentage and strength, number of words learned, and certificates achieved. We use this information to provide you with personalized learning experiences; to track your progress through courses; to enable course completion certificates; and to provide you with performance evaluations.

- Community Interaction Data, including written and spoken exercises submitted for peer correction, feedback provided to other learners, messages sent to other users, and profile information visible to the community

3. Additional Context Regarding Busuu’s Use of Certain Personal Data

In addition to the uses of information described in the Chegg Privacy Policy under section “Our Collection and Use of Personal Data", we use information we collect when you use Busuu in the following ways:

A. Audio-Only AI Pronunciation Assistance Recordings ("Speaking Practice")

The Speaking Practice feature allows you to practice speaking and receive AI-generated feedback on how to improve your pronunciation.

If you choose to use this feature (which is an AI-powered service), your voice will be recorded, retained, and used to provide you with the service you requested (to provide you with feedback on your pronunciation) and to improve our services. Some portions of this feature are powered by service providers, such as Azure AI Speech services. We may also process such audio information to troubleshoot and improve the service by training our machine-learning models with support from expert human reviewers. Such audio information will not be used to uniquely identify you.

B. Audio-Only Community Recordings ("Community Corrections")

The Community Corrections feature allows you to either write or record your voice to submit to other Busuu users for feedback. A proficient speaker of the language you are learning will provide feedback, and in turn, you will also have the opportunity to provide feedback to learners of your own language.

If you choose to participate in the audio component of the Community Corrections feature, your voice will be recorded, retained, and used to provide you with the service you requested and to keep our services safe for all language learners. Additionally, some portions of this feature are supported by service providers for their content moderation services.

C. Audio-Only AI Conversations Recordings ("Conversations")

The Conversations feature allows you to have a conversational, spoken interaction with an AI-powered language partner specific to topics you are learning.

If you choose to use this feature (which is an AI-powered service), your voice will be recorded, retained, and used to provide you with the service you requested (to facilitate interactive conversational scenarios for your language learning) and to improve our services. Some portions of this feature are powered by OpenAI and other service providers. We may also process such audio information to troubleshoot and improve the service by training our machine-learning models with support from expert human reviewers.

D. Agentic AI Language Coach ("AI Coach")

The AI Coach feature allows you to receive personalized coaching powered by artificial intelligence, benefit from lesson content adapted to your proficiency level, get real-time feedback on your speaking and writing, and track your learning progress across sessions.

If you choose to use this feature, we process your voice recordings, text inputs, learning preferences, and performance data as part of our coaching services and to improve our language learning services.

Our AI Coach may automatically adjust lesson difficulty and recommend learning pathways based on your performance. These recommendations are intended to assist your learning journey and will not produce legal or similarly significant effects, and you may review, modify, or override them at any time. Portions of this feature are provided by third-party service providers.

4. Disclosure of Personal Information

In addition to the disclosures of information described in the Chegg Privacy Policy under section “Our Disclosure of Personal Data", we disclose information we collect when you use Busuu in the following ways:

When you use the Busuu service, you may set up your personal profile, connect with other learners, send and receive messages, perform searches and queries, enroll in events and courses, and transmit information through various channels. We display your profile information (except for your email address and password) to other users browsing for connections and to support other site functions.

If your employer or educational institution sponsors your Busuu Premium access, they receive reports about your usage, including learning progress, completion rates, and time spent learning. You will be provided with any legally required notice and rights.

If you participate in live lessons, your video and audio from those sessions are shared with the teacher conducting the lesson.

Per the Chegg Privacy Policy, we do not allow service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Further details on our disclosure of data to third parties are provided in the Chegg Privacy Policy under the "Our Disclosure of Personal Data."

We also engage in online advertising practices (and certain analytics or similar activities) that may be considered "targeted advertising" under certain laws. Details on how to opt out of the processing of your personal information for the purposes of targeted advertising and how to exercise your privacy choices are available in the Chegg Privacy Policy under the "Your Privacy Choices."

We may also disclose your personal data to companies within our holding company and its affiliates.

5. Information for European Union/European Economic Area and United Kingdom Residents

You can find out about the legal bases we rely upon and how they relate to the ways in which we process your information in the Chegg Privacy Policy under the “Additional European Economic Area, United Kingdom Residents, and Switzerland Privacy Policy Disclosures.”

6. Data Privacy Choices

You can learn more about the consumer privacy choices that may be available to you by reviewing the “Your Privacy Choices” section of the Chegg Privacy Policy.

You may, for example, request a copy of the personal information held about you, or request changes or the deletion of your personal data, by completing this form.

7. Mandatory vs. Optional Data

To use Busuu, you must provide your name, email address, and password. Language preferences are also required to deliver the learning service. All other data (profile picture, friend connections, community participation) is optional. If you do not provide mandatory data, you will not be able to create an account or use the service.

8. Age Requirements

Busuu is not directed at children under 13 years of age. In the EEA, users must be at least 16 years old (or the minimum digital consent age in their country) to use Busuu without parental consent.

9. Contact Us

If you have any questions or suggestions regarding our privacy practices, you can contact us by email at privacy@chegg.com, or by writing to us at 5th Floor, Business Cube, 43 Worship Street, London EC2A 2DU, United Kingdom.