Privacy Policy

1. Introduction

At LingoLingo, we take your privacy seriously. This Privacy Policy explains how we collect, use, and protect your personal information when you use our language learning application.

This policy complies with the General Data Protection Regulation (GDPR) and other applicable EU data protection laws. We are committed to protecting your privacy and ensuring transparency in our data processing activities.

2. Data Controller Information

Data Controller: LingoLingo
Address: cde0f8e9feacdce3fff8fbe9ebacbebab4a0acbeb4bebcbbaccefee9e1e9e2a0accbe9fee1ede2f5
Email: f4f5dcf0f5f2fbf3f0f5f2fbf3b2fdecec
Website: https://lingolingo.app

If you have any questions about this Privacy Policy or our data processing activities, please contact us using the information above.

3. Information We Collect

3.1 Personal Information You Provide

• Account Information: Email address, username, and password when you create an account
• Profile Information: Language preferences, learning goals, and study preferences
• User-Generated Content: Flashcards, notes, and study materials you create
• Communication Data: Messages you send to us for support or feedback

3.2 Information Collected Automatically

• Usage Data: How you interact with our app, features used, and learning progress
• Device Information: Device type, operating system, browser type, and IP address
• App Performance Data: Basic app functionality and error reports for service improvement
• Location Data: General location information (country/region level only)

3.3 Information from Third Parties

• Authentication Providers: Information from Apple Sign-In or Google Sign-In when you use these services
• YouTube Integration: Video content, transcripts, and metadata accessed through YouTube's embedded player and API services
• Translation Services: Text content processed through third-party translation APIs

4. Legal Basis for Processing

We process your personal data based on the following legal grounds under GDPR:

4.1 Consent

We process certain data based on your explicit consent, such as marketing communications and optional analytics tracking.

4.2 Contract Performance

We process data necessary to provide our language learning services and fulfill our contractual obligations to you.

4.3 Legitimate Interest

We process data for our legitimate interests in improving our services, ensuring security, and preventing fraud, provided these interests do not override your fundamental rights and freedoms.

4.4 Legal Obligation

We may process data to comply with legal obligations, such as tax requirements or responding to lawful requests from authorities.

5. How We Use Your Information

5.1 Service Provision

• Provide personalized language learning experiences
• Create and manage your account and profile
• Process payments and manage subscriptions
• Provide customer support and technical assistance

5.2 Service Improvement

• Analyze usage patterns to improve our app functionality
• Develop new features based on user feedback and behavior
• Conduct research to enhance language learning effectiveness
• Optimize app performance and user experience

5.3 Communication

• Send important service updates and notifications
• Provide educational content and learning tips
• Respond to your inquiries and support requests
• Send marketing communications (with your consent)

5.4 Security and Compliance

• Protect against fraud, abuse, and security threats
• Comply with legal obligations and regulatory requirements
• Enforce our terms of service and policies
• Investigate and resolve disputes or complaints

6. Data Sharing and Third Parties

6.1 Service Providers

We share data with trusted service providers who assist us in operating our app:

• Cloud Hosting: Hetzner Online GmbH (Germany) for data storage and processing
• Payment Processing: RevenueCat for subscription management and Apple/Google for payment processing
• Translation Services: Third-party APIs for translation functionality (only non-personal video content)

6.2 Data Processing Limitations

We do not share personal data with translation services. Only anonymized video content (transcripts, subtitles) is processed through translation APIs for language learning purposes. No personal information is transmitted to these services.

6.3 Legal Requirements

We may disclose your information if required by law, court order, or government request, or to protect our rights, property, or safety.

6.4 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of the business transaction, subject to the same privacy protections.

7. YouTube Integration and Compliance

Our app integrates with YouTube to provide language learning content through embedded video players. This integration is subject to YouTube's Developer Policies and Terms of Service.

7.1 YouTube Data Processing

When you use our app to watch YouTube videos for language learning:

• YouTube may collect and process your data according to their own Privacy Policy
• We do not collect or store your YouTube viewing history or personal data from YouTube
• YouTube's embedded player may use cookies and tracking technologies
• Video metadata (titles, descriptions, thumbnails) is accessed through YouTube's API for educational purposes

7.2 YouTube Compliance

Our YouTube integration complies with YouTube's Developer Policies:

• We respect user privacy and do not harvest or track personal data from YouTube
• We maintain standard YouTube player functionality without modification
• We provide independent educational value beyond YouTube's standard features
• We do not circumvent YouTube's restrictions or violate their Community Guidelines

7.3 YouTube Terms

By using our app's YouTube integration, you also agree to YouTube's Terms of Service and Privacy Policy. You can review these at YouTube Terms of Service and Google Privacy Policy.

8. International Data Transfers

Your data may be transferred to and processed in countries outside the European Economic Area (EEA). We ensure appropriate safeguards are in place:

7.1 Adequacy Decisions

We transfer data to countries that have been deemed adequate by the European Commission, such as Canada and Switzerland.

7.2 Standard Contractual Clauses

For transfers to countries without adequacy decisions, we use Standard Contractual Clauses (SCCs) approved by the European Commission.

7.3 Additional Safeguards

We implement additional technical and organizational measures to protect your data during international transfers.

9. Data Security

We implement industry-standard security measures to protect your personal information:

• Encryption: Data is encrypted in transit (TLS/SSL) and at rest (AES-256)
• Access Controls: Strict access controls and authentication mechanisms
• Regular Audits: Security assessments and penetration testing
• Data Minimization: We only collect and retain data necessary for our services
• Incident Response: Procedures for detecting and responding to security incidents

While we strive to protect your data, no method of transmission over the internet is 100% secure. We cannot guarantee absolute security but commit to promptly notifying you of any security breaches that may affect your personal data.

10. Data Retention

We retain your personal data only as long as necessary for the purposes outlined in this policy:

• Account Data: Retained while your account is active and for 30 days after deletion
• Usage Data: Retained for 2 years for service improvement purposes
• Payment Data: Retained for 7 years to comply with tax and accounting requirements
• Support Communications: Retained for 3 years to provide ongoing support
• Marketing Data: Retained until you withdraw consent or unsubscribe

After the retention period, data is securely deleted or anonymized. You may request deletion of your data at any time, subject to legal requirements.

11. Your Data Protection Rights

Under GDPR, you have the following rights regarding your personal data:

10.1 Right of Access

You can request a copy of your personal data and information about how we process it.

10.2 Right to Rectification

You can request correction of inaccurate or incomplete personal data.

10.3 Right to Erasure

You can request deletion of your personal data in certain circumstances.

10.4 Right to Restrict Processing

You can request that we limit how we process your personal data.

10.5 Right to Data Portability

You can request a copy of your data in a structured, machine-readable format.

10.6 Right to Object

You can object to processing based on legitimate interests or for direct marketing.

10.7 Right to Withdraw Consent

Where processing is based on consent, you can withdraw consent at any time.

10.8 Right to Lodge a Complaint

You have the right to lodge a complaint with your local data protection authority.

12. Exercising Your Rights

To exercise your data protection rights, contact us at f4f5dcf0f5f2fbf3f0f5f2fbf3b2fdecec. We will respond to your request within 30 days, unless the request is complex, in which case we may extend the response time by up to 60 days.

We may need to verify your identity before processing certain requests to protect your privacy and security.

You can also manage many of your privacy preferences directly in the app settings.

13. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your experience:

12.1 Essential Cookies

These cookies are necessary for the app to function properly and cannot be disabled. They include session management, authentication, and basic app functionality.

12.2 Functional Cookies

These cookies enhance your user experience by remembering your preferences, language settings, and learning progress.

12.3 Third-Party Cookies

We may use third-party cookies for payment processing (RevenueCat, Apple/Google) and translation services. These are subject to the respective third-party privacy policies.

14. Children's Privacy

Our app is not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13.

If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately. We will take steps to remove such information from our records.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. We will notify you of any material changes by:

• Posting the updated policy on our website
• Sending you an email notification
• Displaying a notice in the app

Your continued use of our app after any changes constitutes acceptance of the updated Privacy Policy.

16. Contact Information

If you have any questions about this Privacy Policy or our data practices, please contact us:

• Email: f4f5dcf0f5f2fbf3f0f5f2fbf3b2fdecec
• Address: cde0f8e9feacdce3fff8fbe9ebacbebab4a0acbeb4bebcbbaccefee9e1e9e2a0accbe9fee1ede2f5
• Website: https://lingolingo.app

For EU residents, you may also contact your local data protection authority if you have concerns about our data processing activities.