Terms of Service

1. The parties, and who may use LingoDesk

In short: this section says who you would be contracting with — Espinosa Bookkeeping LLC, doing business as LingoDesk — and who may open an account. This lead-in is explanation; the text below it governs.

LingoDesk is a business-management service for freelance translators, operated by Espinosa Bookkeeping LLC, a limited liability company doing business as LingoDesk, located in Las Vegas, Nevada, United States. In these terms “we”, “us” and “our” mean Espinosa Bookkeeping LLC, and “you” means the person or entity that opens the account.

Who you are contracting with

The contracting entity is Espinosa Bookkeeping LLC, a limited liability company, doing business as LingoDesk. The same identity is published in section 1 of our Privacy Policy. Our mailing address is LingoDesk, PO Box 335208, North Las Vegas, NV 89033, United States. Card and bank statements show a charge from us as LINGODESK. Las Vegas, Nevada appears above because it is why Nevada law governs these terms.

These terms are written for people buying for their business

LingoDesk is sold to translators for use in their work, so we assume you are acting in the course of your trade, business, craft or profession. Under Article 2 of Directive 2011/83/EU a consumer is a natural person acting for purposes outside their trade, business, craft or profession — so on that assumption you are not a consumer, and the statutory withdrawal right does not attach to this purchase.

We are stating that assumption openly rather than relying on it silently. It will not hold for everyone: a part-time translator with a separate day job may fall inside the dual-purpose case, where the trade purpose is not the predominant one. Where consumer protections do apply to you, nothing in these terms excludes or limits them. An attempt to contract out of a mandatory consumer right is unenforceable, so we do not attempt one.

Eligibility

• You must be at least 18 years old and legally able to enter into a contract.
• If you open an account on behalf of a company or partnership, you confirm you are authorised to bind it, and “you” means that organisation as well as you personally.
• One account per person or entity. Your sign-in details are yours alone and must not be shared; you are responsible for what is done through your account.
• The email address on the account is how we reach you. Keeping it current is your responsibility, and notices we send to it count as given.

2. The service

In short: this section describes what the software actually does today. It is deliberately a description and not a promise about what it will do later.

LingoDesk is a business-management tool. It is not a translation tool: it does not translate anything, and it is not a computer-assisted translation environment. What it does is the paperwork around the work:

• Invoicing. Per-word pricing with fuzzy-match tiers, and rate cards you define per client, turned into invoices and credit notes.
• Money across currencies. Multi-currency invoicing with recorded exchange rates, and revenue tracked in your home currency.
• Clients and projects. A client record, project records and a deadline calendar.
• Documents and exports. PDF invoice generation carrying your business name, address and bank details, and revenue reports exported as CSV.

That list describes the service as it stands on the effective date of these terms. We may add, change or withdraw features. If we withdraw something you rely on, you may cancel under section 4; that is the remedy, and we are not going to pretend the feature set is frozen when it is not.

Nothing outside this document forms part of it. Marketing pages, screenshots and documentation describe the service but do not add terms to this contract, and where they disagree with this document, this document governs.

3. Subscription and billing

In short: LingoDesk is a subscription that renews by itself until you stop it. This section sets out what we tell you before we charge you, what you agree to, and how the renewal works.

Selling a subscription that renews automatically carries three specific duties under 15 U.S.C. §8403, and cancellation carries a fourth under California AB 2863, which amended that state's Automatic Renewal Law with effect from 1 July 2025. The three billing duties are discharged here, in order; the fourth is section 4.

(1) We disclose the material terms before we take your billing information

§8403(1) requires text that clearly and conspicuously discloses all material terms of the transaction before obtaining your billing information. Before you enter any payment details you are told: what the subscription includes; the length of the billing period; that the subscription renews automatically at the end of each period; the price, which is the price shown at the point of purchase; and how to stop it.

This document does not state a price. That is deliberate. The price you pay is the one displayed to you at the point of purchase and confirmed in your receipt. A price written into a contract is a second copy of a number that lives in a payment system, and two copies drift; we would rather point you at the authoritative one than publish a figure that can quietly stop being true. Our build fails if a price literal is ever added to this page.

(2) You give express consent to the recurring charge

§8403(2) requires your express informed consent before we charge you. That consent is taken at the point of purchase, as a distinct affirmative act, for a charge that is described to you as recurring. We never start a subscription on your behalf, and we never convert a free account into a paid one without you doing something that says so.

(3) The subscription renews automatically until you cancel

At the end of each billing period the subscription renews automatically for another period of the same length, and the same amount is charged again, until you cancel it under section 4. There is no fixed term and no minimum number of periods.

How the money moves

• Payments are taken by our payment provider, not by us. Your card number, security code and expiry date are entered with that provider and never reach LingoDesk servers. We hold the customer and subscription identifiers it issues us, and nothing else about the card.
• Charges are in US dollars, whatever currency you invoice your own clients in. Your bank may apply its own conversion or cross-border fee, which is between you and your bank.
• The renewal price is the price you were shown at the point of purchase. If we change it, we will tell you in advance under section 12, and the new price applies only from a renewal that falls after the notice period ends — so you can always cancel before a changed price is charged.
• A failed payment does not silently end the subscription. If a charge fails, we may retry it and may suspend access under section 9 until it succeeds.

4. Cancellation

In short: you can stop the subscription whenever you like, it then does not renew, and you keep access until the end of the period you have already paid for. Writing to us always works. There is also a billing-portal control in the product, and this section is honest about what we have and have not verified about it.

You may cancel at any time. You do not have to give a reason, and there is no cancellation fee and no notice period to serve.

What cancelling does:

• The subscription does not renew at the end of the current billing period.
• Your access continues until the end of the period you have already paid for. Cancelling does not cut you off on the day you ask.
• After that date the account stops being a paying account and section 7 and section 9 govern what happens to your data.

How to cancel, and what we can and cannot promise about it

Two routes, and we are describing both accurately because an earlier version of this clause described neither.

• By writing to us — guaranteed. Write to support@lingodesk.net from the email address on the account and say you want to cancel. We will acknowledge it and stop the renewal. A request that reaches us before your next renewal date takes effect from that date. This route is entirely within our control, so it is the one we commit to.
• Through the billing portal — present, but not yet confirmed by us. The billing page inside the product has an Open billing portal control that hands you to our payment provider's own portal for your subscription. What that portal offers you — updating a card, changing plan, cancelling — is a configuration on the provider's dashboard, and we have not read that configuration off. The product's own interface currently tells you the portal will let you cancel; until we have verified that against the dashboard we are not going to repeat that promise in a contract.

Until this document was independently audited it said, flatly, that no control inside the product ends a subscription. That was wrong: the control is there and has been since before these terms were published. We are correcting it here rather than quietly, and we are not replacing one unverified sentence with another.

Why the difference matters to you and not only to us. §8403(3) requires simple mechanisms to stop recurring charges, and California's Automatic Renewal Law as amended by AB 2863 requires termination to be available "exclusively online, at will, and without engaging any further steps that obstruct or delay", in the same medium the customer used to sign up — signing up online means being able to stop online. A portal that offers cancellation satisfies that; a portal that does not, does not, and an email address on its own does not either. So the open question is not whether to build something. It is whether the thing already built does what its own button says. Confirming the payment provider's portal configuration is recorded as an open item that must be closed before the service is offered for sale, and until it is, the written route above is the one we stand behind.

Refunds

We do not refund a period that has already begun, because cancelling leaves your access running to the end of it — you keep what you paid for rather than handing it back. Two things we do refund, on request and without argument:

• a charge taken in error, including a renewal charged after we received a cancellation;
• a period during which the service was unavailable to you for an extended time through our fault, refunded in proportion to the time lost;
• the unused part of a period, where you leave because we changed something you had a right to object to — the sub-processor objection route in section 14(d) is the case that produces this.

Where a mandatory consumer right gives you a stronger refund entitlement than this section, that right applies and this section does not reduce it — see section 1.

5. Acceptable use

In short: use the service for your own translation business, and do not attack it or the people on it. This list is short because it is meant to be read.

You agree not to:

• use LingoDesk for anything unlawful, or to store or send unlawful content;
• attempt to reach another customer's data, or to defeat the separation between accounts, whether by probing the product, by manipulating identifiers or by any other means;
• scrape the service, or obtain programmatic access to it other than through an interface we have published for that purpose;
• resell, sublicense or rent access to your account, or share it with people outside your business;
• upload or distribute malware, or use the service to deliver an attack on anyone;
• interfere with the operation of the service, including by placing load on it deliberately.

If you breach this section we may suspend or end your account under section 9. An attempt to reach another customer's data is the one item on this list we will act on immediately rather than after notice, because the customer at risk is not you.

6. Intellectual property

In short: the software is ours, the data you put into it is yours, and we do not take a licence to your data beyond running the service for you.

The software, its design, its brand and its documentation are ours and stay ours. Your subscription is a right to use the service while it is paid for; it does not transfer any ownership, and it does not let you copy, decompile or rebrand the product.

The data you enter is yours — your clients, your projects, your invoices, your rates, your notes. We claim no ownership of it. We process it only to run the service for you, and to do the things you use the product to do: produce your invoices, send the messages you ask us to send, show you your own records.

We do not use your data for our own purposes. No product analytics built on your records, no benchmarking, no aggregate insights sold or published, no model training, no enrichment, no resale. This is a present commitment and not a courtesy: Article 28(10) provides that a processor which "infringes this Regulation by determining the purposes and means of processing … shall be considered to be a controller in respect of that processing" — so using your clients' data for our own ends would change what we are, not merely what we do. Section 14 restates this as an operative term.

If you send us feedback or a feature suggestion, we may act on it without owing you anything for it. We are saying so plainly because the alternative is a clause nobody reads that says the same thing at greater length.

7. Your data

In short: getting your data out is possible but not automatic, and this section says exactly how automatic it is rather than implying more.

Your records stay yours throughout. What follows is about getting hold of them and getting rid of them.

What you can export yourself, today

• Every invoice as a PDF document, at any time.
• Revenue reports as CSV files.

Credit notes are not among them, and this clause said they were until it was audited. The product generates PDFs for invoices only. A credit note you have issued is visible in the product and can be sent to us for a copy, but there is no PDF export button for one, and we are not going to leave a sentence standing that says otherwise.

There is no one-click export of your complete record. The two mechanisms above cover invoice documents and reporting; they are not a full copy of everything in the account. We would rather tell you that than let the word “export” imply something wider than it is.

A full export, or deletion

A complete export, or deletion of your data, is handled manually. Write to support@lingodesk.net and we will do it by hand, within 30 days of a request we can verify. Article 12(3) allows one month for a data-subject request, extendable by two further months where the request is complex or numerous; 30 days is inside that and shorter than a calendar month in most of the year. We apply the tighter figure to these requests too rather than working to a longer one.

One person does this work, so the honest description is that it is a manual process with a stated turnaround, not an automated pipeline. Where the data concerned is your clients' data rather than your own, the corresponding obligation to you as controller is in section 14(e) and (g), and our Privacy Policy covers the data we hold about you.

8. Availability

In short: we try hard to keep the service up, and we are not going to put a number on it that we have no way to measure.

We will use commercially reasonable efforts to keep LingoDesk available. We do not promise a particular level of availability, and there is no service-level agreement attached to these terms.

The reason is worth saying rather than hiding. We do not operate uptime monitoring or a public status page, so we could not measure a percentage, report against it or tell you when we had missed it. A figure we cannot observe would be decoration, and a commitment nobody can check is worth less than an honest description. If that changes, this section changes with it.

Planned maintenance will be announced in advance where that is practicable, by email to account holders. Unplanned interruptions, and interruptions caused by our hosting or payment providers, are not always within our control. Where an extended outage is our fault, section 4 sets out the refund position.

9. Suspension and termination

In short: we can suspend or close an account in a small number of named situations, we will tell you where we can, and you get a window to take your data with you.

We may suspend your access, or end this contract, if:

• a subscription payment fails and is not made good;
• you breach section 5;
• we are required to by law, by a court, or by a provider we depend on to run the service.

We will tell you before we suspend, where that is practicable, and tell you what would resolve it. We will not do it silently. Where the reason is an attempt to reach another customer's data, we will act first and tell you immediately afterwards.

You may end this contract at any time by cancelling under section 4.

What happens to your data

After the contract ends we keep your data for 30 days, during which you may write to us and ask for an export or for deletion under section 7. After that window we delete it, except where we are legally required to keep something — an invoice we issued to you, for example, is a record we may have to retain. Where the data is your clients' data, section 14(g) governs, and it gives you the choice between deletion and return.

10. Warranties and liability

In short: the service is provided as it is, our financial exposure is capped by reference to what you have paid us, and we are telling you openly that how far clauses like this hold up is a question we have not had reviewed.

The service is provided as it is and as available. To the extent the law allows, we exclude implied warranties of merchantability, fitness for a particular purpose and non-infringement. We do not warrant that the service will be uninterrupted or error-free, and we do not warrant that any calculation it performs is correct for your tax or accounting purposes — the invoices you issue are yours, and checking them is your job.

Our total liability to you, for all claims taken together, is limited to the amount you have actually paid us for the service in the twelve months before the claim arose. That is a formula and not a number, deliberately: it moves with what you pay rather than sitting in this document going stale.

We are not liable for indirect or consequential loss, for loss of profit, revenue, goodwill or anticipated savings, or for loss or corruption of data to the extent it could have been avoided by keeping your own copies. Nothing here limits liability that cannot lawfully be limited — including for death or personal injury caused by negligence, and for fraud.

This is the clause we are least able to vouch for

Whether limitations and disclaimers of this kind are enforceable varies by governing law, and it varies more than most terms do. A cap that is ordinary under Nevada law may be read differently under EU unfair-terms rules, particularly against a customer who turns out to be a consumer after all. Nothing in this section has been reviewed by a qualified lawyer. We are marking it as a judgement rather than dressing it up as settled, and it is recorded as an open item rather than resolved by the fact that we wrote it down confidently.

11. Tax

In short: the price does not include any tax you may owe, and we are not collecting it for you. If you are registered for VAT or an equivalent, that remains your affair.

Prices are exclusive of any tax you may owe on the purchase. Any sales tax, value-added tax, goods-and-services tax or equivalent that applies to you in your own country is yours to account for.

We are not a merchant of record, and neither is our payment provider. That means we do not collect or remit VAT on your behalf, we do not operate a one-stop-shop registration, and you should not read anything in the checkout as VAT having been handled for you. We are saying it in those words because the opposite is what a customer reasonably assumes when a large payment company takes the money.

Whether the service itself is subject to sales tax in our own state is a determination we have not settled, and it is an accountant's question rather than a lawyer's. It is recorded as an open item. It does not change the sentence above: what you owe where you are is still yours.

The tax fields inside the product — your tax identifier, your clients' VAT numbers, reverse charge, tax rates on your own invoices — are yours to set and yours to get right. The software does the arithmetic you tell it to do; it does not advise you, and section 10 means what it says about that.

12. Changes to these terms

In short: we can change these terms, we tell you first, and carrying on using the service after the change is how you accept it. There is one honest wrinkle about email, below.

We may change these terms. When we do, we will:

• email account holders at least 30 days before the change takes effect, where the change is material;
• republish this document with a new effective date at the top;
• add a dated row to the changelog in section 15 describing what changed.

Continuing to use LingoDesk after the new effective date is how you accept the change. If you do not accept it, cancel under section 4 before that date and the old terms govern the rest of your paid period. A change that affects the price is handled the same way, so a price change can never take effect on you without a renewal you had the chance to stop.

Corrections that do not change anyone's rights — a typo, a broken link, a clearer sentence — get a changelog row without an email.

Email delivery is switched on. Messages are sent through the email provider named in section 5 of our Privacy Policy, and every send is recorded with its outcome in the log described there. The email above is how you hear about a material change; the changelog below remains the permanent record of what changed and when.

13. Governing law

In short: Nevada law governs, disputes go to the courts of Clark County, and if you are protected by mandatory rules where you live, those still apply to you.

These terms are governed by the laws of the State of Nevada, United States, without regard to its conflict-of-laws rules. The courts of Clark County, Nevada have jurisdiction over disputes arising out of them.

That choice reflects where the operator is established, and nothing more. It has not been reviewed by counsel, and it is not a claim that a Nevada forum is convenient for you or enforceable against you wherever you are. It is recorded as an open item, and we would rather state the basis for it than present it as though it had been advised.

Mandatory rules where you live are not displaced by this section. If the law of your own country gives you protections that cannot be contracted away — including the right to bring proceedings in your local courts where that right applies to you — you keep them, and this section does not take them from you. Nor does it displace the rights of the people whose personal data you process through the service; those are governed by section 14 and by the law that applies to them.

14. Data-processing terms (Article 28)

In short: when you put your clients' details into LingoDesk, you are the one answerable for them and we are working for you. This section is the contract that Article 28 of the General Data Protection Regulation requires in that situation. It is part of these terms and is accepted with them.

Which of us is which

Getting that round the wrong way is the error a reader who works with these documents professionally spots first, which is why it is the first thing in this section rather than buried in it.

The processing, described

Article 28(3) requires the contract to set out six things about the processing. None of them is left blank here:

Subject matter

Providing the LingoDesk service to you under these terms.

Duration

The life of your account. Processing ends when the contract ends, after which sub-clause (g) below governs what happens to the data.

Nature and purpose

Storing, organising, retrieving and transmitting client, project, invoice, credit-note and payment records, and generating and delivering invoices and related messages — on your instructions, for the purpose of running your translation business.

Type of personal data

Contact details (names, contact names, email addresses, telephone numbers), postal addresses, tax and VAT identifiers, payment references, and free-text notes whose content you determine.

Categories of data subjects

Your clients and their named contacts. Where a client is recorded as an individual rather than a company, that client is themselves a natural person.

Your obligations and rights as controller

You give the instructions, and you are responsible for having a lawful basis for the processing you ask for and for telling your own clients what you do with their data — Article 13 runs from you to them, not from us. Your rights are the ones set out in the eight sub-clauses below, and they are exercisable by writing to support@lingodesk.net.

(a) We process only on your documented instructions

We process your clients' personal data only on your documented instructions, including as to any transfer to a third country. Using the service is the instruction: creating a client, issuing an invoice or sending a reminder each instructs us to carry out the processing that action requires. Anything beyond that needs a separate written instruction from you.

We do not inspect, index or classify the free-text fields. Notes on clients, projects, invoices, credit notes and payments accept whatever you type, up to and including special categories of personal data under Article 9. Nothing in the product reads them, searches them for meaning or categorises them. You decide what goes in them, and that is a real decision rather than a formality: a note about a client's health or circumstances is data we will hold and never look at, and its being there is your call, not ours.

The duty runs the other way too. If an instruction appears to us to infringe the Regulation, we will inform you immediately — the closing words of Article 28(3), attached there to point (h) rather than to this one, require it in exactly those terms, and it is the sentence that stops "you told us to" being an answer to everything.

(b) Confidentiality

One person operates this service, and that person is bound to keep your clients' data confidential. We are writing it that way rather than as a sentence about personnel subject to confidentiality obligations, because there are no personnel: a template sentence about a company that does not exist would be less true, not more professional. The undertaking is personal, it is not limited in time, and it survives the end of this contract. Nobody else has access to the production system.

(c) Security measures

Article 32 requires measures appropriate to the risk. The list below is what is actually implemented, read out of the code rather than out of a template:

• Account separation enforced at the data layer. Every query is filtered by account at the level of the data-access layer itself, not by each screen remembering to do it, so one customer's records cannot be returned to another by a mistake in a single query.
• Password policy. At least 8 characters, requiring a digit, an upper-case letter, a lower-case letter and a non-alphanumeric character; passwords are stored as hashes and never in readable form.
• Lockout. Five failed sign-in attempts lock the account for 15 minutes, which is what makes automated password-guessing impractical.
• Session cookies are httpOnly, marked secure and restricted to same-site requests in production, so a script on another page cannot read them.
• Session rotation. Access sessions are short-lived and refreshed; refresh tokens rotate on use, and a scheduled job deletes expired and revoked ones 30 days later.

What is not on that list is not being claimed. We hold no security certification, we have not commissioned an independent security assessment, and we do not operate a formal information-security management system. A measure we have not implemented is a measure we do not list, and we would rather this section be shorter than most and true than longer than most and aspirational.

(d) Other processors we use

Article 28(2) says we may not engage another processor without your authorisation, and that where the authorisation is general we must tell you about changes and give you the chance to object. Here is how that works in practice rather than in principle:

• You give general written authorisation by accepting these terms, for the other processors currently listed.
• The current list is published, named individually, in section 5 of our Privacy Policy — the hosting and database provider, the payment provider and the email provider — together with what each one actually receives, which for the email provider is the recipient address, the subject and the full rendered body of each message sent.
• We will tell you at least 30 days before we add or replace one, by email to account holders. That period is our choice, not a statutory minimum; the Regulation requires only that you get enough notice to object. We have recorded it as an open item so that it is reviewed before the first payment is taken, and we can only ever change it by giving notice under section 12.
• You may object by replying to that notice. If we cannot accommodate your objection, you may end this contract without penalty and we will refund the unused part of your current period under section 4 — you would be leaving over a change we made, so you should not pay for the rest of a period you no longer want.
• We remain fully liable to you for their performance. Article 28(4) puts the obligation there and we are not trying to move it: if a provider we chose fails to meet its data-protection obligations, that is our failure to you, not a matter between you and them.

Our email provider engages its own providers in turn, and that third tier matters to you because the body of every invoice we send passes through it. Its current list is published at resend.com/legal/subprocessors. We link it rather than copying it here: a transcribed list goes stale silently, and a stale list is worse than a link because it looks current.

(e) Helping you answer your clients' requests

Where one of your clients exercises a right — access, rectification, erasure, portability, objection — the request is yours to answer, and we will help you answer it.

There is no self-service export or erasure mechanism in the product, and we are not going to describe one. Assistance is manual: write to support@lingodesk.net telling us what you need, and we will extract, correct or delete the records by hand within 30 days. Article 12(3) gives you one month to reply to your own client, so a 30-day turnaround from us is slightly inside your own deadline rather than equal to it — which is the point, so that our time does not consume yours. If a request is unusually large we will tell you at once rather than at the end of the period.

(f) Helping you with security and breach notification

We will assist you with your obligations under Articles 32 to 36, taking into account the nature of the processing and the information available to us.

If personal data you have entrusted to us is breached, we will notify you without undue delay after becoming aware of it, with what we know: what happened, which categories of data and roughly how many records are affected, the likely consequences and what we are doing about it — the information Article 33 requires you to give your supervisory authority. Article 33(2) is the source of that standard in those words: "The processor shall notify the controller without undue delay after becoming aware of a personal data breach."

A second law sets a stricter clock on the same event, and we are not going to imply one notification quietly satisfies both.NRS 603A.220(2) requires a data collector that maintains personal information it does not own to notify the owner "immediately following discovery" — a tighter word than "without undue delay", and an earlier version of this clause asserted that our Article 33(2) notification discharged it. Where both apply, we work to the stricter of the two and tell you as soon as we know, rather than treating the looser standard as the ceiling.

We deliberately do not publish a fixed number of hours here. The database is operated by a hosting provider, a breach could originate there and be discovered late, and a self-imposed deadline that is missed is a second failure on top of the first. "Without undue delay after becoming aware" is the standard the Regulation sets, it is the one we can actually meet, and we would rather commit to it honestly than publish a number that reads better.

(g) Deletion or return at the end

When this contract ends, you choose: deletion or return of your clients' personal data. Tell us which by writing to support@lingodesk.net. Return means an export of the records; deletion means deletion, including of existing copies.

As with (e), this is a manual process carried out by hand within 30 days of a request we can verify. Section 9 holds the data for 30 days after the contract ends so there is a window in which to ask; if you tell us nothing in that window, we delete.

Two exceptions, both named rather than left to be discovered. We keep what the law requires us to keep — records of the invoices we issued to you, for example. And the log of messages the product has sent stores the full rendered body of each message, which for an invoice includes your bank details and your client's name and address; that log has no automatic deletion schedule today. It is recorded as an open item with a fix attached rather than presented as a design decision, and section 7 of our Privacy Policy says the same thing about it.

(h) Information and audits

We will make available to you the information necessary to demonstrate that we comply with this section, and we will respond in writing, within a reasonable time, to reasonable questions about how the service handles your clients' data — including questions your own auditor or a client of yours puts to you.

This is where we are narrower than a large provider's terms, and we are saying so instead of copying theirs. Article 28(3)(h) does not merely contemplate audits — that is how this clause put it until it was audited, and it understated the Article. It requires the contract to stipulate that the processor "makes available to the controller all information necessary to demonstrate compliance with the obligations laid down in this Article and allow for and contribute to audits, including inspections, conducted by the controller or another auditor mandated by the controller". One person operates this service; a commitment to host an inspection would be a commitment we could not honour at scale, and an unhonourable clause is worth less to you than an honest one. So what we commit to is documentary evidence and a written response. That limitation is a known deviation from the Article's full breadth, it is recorded as an open item, and a customer for whom it is not enough should tell us before subscribing rather than after.

We do not use your clients' data for ourselves

We do not determine the purposes or means of processing your clients' data, and we do not use that data for our own purposes. No aggregate benchmarking, no cross-customer insights, no model training, no enrichment, no resale. Article 28(10) provides that a processor which "infringes this Regulation by determining the purposes and means of processing" is considered a controller in respect of that processing — the breach limb is part of the provision and we are not dropping it. So this is not a courtesy, it is the sentence that keeps us on the correct side of the split described at the top of this section. As at the effective date of these terms it is verifiable in the product itself: there is no profiling, scoring, benchmarking or model-training code in it.

How these terms are formed, and what has not been checked

These terms are presented and accepted electronically. Article 28(9) requires the processor contract to be in writing, including in electronic form, and this document is intended to be that contract rather than a description of one.

Whether this presentation forms a binding processor contract with each customer, and whether another processor's own published list may be incorporated by reference the way sub-clause (d) does, has not been reviewed by counsel. We are naming that rather than letting the format imply otherwise; both questions are recorded as open items. If you need a separately executed data-processing agreement — because your own client requires one, or because your compliance process does — write to support@lingodesk.net and we will deal with it directly.

15. Effective date and changelog

In short: these terms take effect on 17 August 2026, and every change to them from now on gets a dated line in the table below.

The effective date of these terms is 17 August 2026; they were last updated on 27 August 2026.

These pages are structurally complete and pending professional review before the first payment is taken. Everything above is written from the code as it actually is, with a citation on every claim of law, and nothing on it has been reviewed by a qualified lawyer. We are telling you that rather than letting the format imply otherwise.