A privacy policy you can actually read.

1. Overview

LinguaDig ("we", "us", "our") is a personal English-learning platform that helps you read, write, speak, listen, review with spaced repetition, and prepare for IELTS, TOEFL, and PTE. This Privacy Policy explains what information we collect, how we use it, who it is shared with, and the controls you have.

This policy is version-stamped. The version you are reading is 2026-05-v1.0, effective 2026-05-05. Once a version has been agreed to by a user it cannot be altered — substantive changes are published as a new version and you'll be asked to review and re-agree.

If anything is unclear, the in-app Support page is one click away and we'll answer in plain English.

2. Information we collect

We collect only the data necessary to operate, secure, and personalise the service. The table below summarises every category, paired with the legal basis (under GDPR Art. 6) and how long we keep it.

3. Why we collect it

• To deliver the core learning experience — flashcards, reviews, AI feedback, spaced-repetition reminders, exam-style practice.
• To personalise content based on your CEFR level, native language, and learning goals (e.g. recommend a passage rich in your weakest phonemes).
• To process subscriptions — confirm payments, manage period dates, apply promotions or coupons.
• To keep the service secure — detect abuse, prevent fraud, protect your account.
• To communicate essential service notices (review reminders are opt-in; billing notices are not).
• To meet our legal obligations (e.g. accounting, lawful disclosure, takedown notices under DMCA / EU DSA).

4. Legal basis (GDPR Art. 6)

Under the EU General Data Protection Regulation (Reg. 2016/679) and the UK GDPR, we rely on the following lawful bases:

• Art. 6(1)(b) — performance of contract: for delivering the learning experience, processing payments, and operating your account.
• Art. 6(1)(a) — consent: for opt-in marketing emails, voice-clone biometric data (also Art. 9(2)(a) explicit consent), and any future opt-in research feature.
• Art. 6(1)(c) — legal obligation: for tax and accounting records, lawful information requests, takedown response.
• Art. 6(1)(f) — legitimate interest: for product analytics (anonymised), security and abuse prevention. We balance these interests against your rights — you can object to any processing under this basis at any time.

Where we process special-category data (currently: voice clones), we additionally rely on Art. 9(2)(a) — your explicit, separate consent collected at the point of recording.

5. How we use your information

Your data is used only to power the service for you:

• Producing AI feedback — your essays and recordings are sent to our AI grader, which returns per-sentence corrections, scored rubrics, and explanations in your native language.
• Running the spaced-repetition queue — scheduling reviews based on your scores.
• Recommending content — passages, videos, and idioms aligned to your weak spots.
• Processing crypto subscriptions through NOWPayments and confirming when payments clear.
• Showing your private learning history and stats (only to you, never to other users unless you opt-in to share).
• Detecting abuse and operating the service safely.

We do not use any of your data for cross-context behavioural advertising or profile-based decisions that have legal or similarly significant effects (GDPR Art. 22).

6. When you upload content

This is the most important section if you use Source Studio, Reading, Speaking, or any feature where you upload a file or paste a URL.

When you upload a file or paste a URL, we extract its text / audio / transcript and store it as a Learning Source (or, depending on the surface, a Reading Passage, Video Lesson, Journal Entry, etc.) under your private account. We use it to generate flashcards, summaries, quizzes, and AI feedback FOR YOU. We never sell your uploads. We never use your private uploads to train third-party AI models without your explicit opt-in.

Specifically:

• Encryption: uploads travel over TLS 1.3 and are stored encrypted at rest with AES-256 on the Base44 platform — full controls listed in our Security Policy.
• Visibility: only you can read your private uploads. Administrators may view aggregated, anonymised metrics for product improvement, but never your individual content.
• Deletion: any uploaded source can be deleted from its detail page. Account deletion purges all uploads within 30 days.
• AI processing: when you trigger an AI action (e.g. summarise, transcribe, grade), the relevant text or audio is sent to a sub-processor (typically OpenAI) over an encrypted connection. The sub-processor returns a response and does not retain it for model training (see §8).
• Public sharing is opt-in: if you choose to publish a source to the community library, that is a second, separate consent — captured by the community-share gate — that explicitly licenses the content for public access. You can revoke a public share any time.
• Third-party rights: when you upload, you confirm you have the right to do so. We have a notice-and-action mechanism (see Terms §10) for rights-holders to request takedown.

7. What each feature processes

The "Exactly what each feature processes" cards above are the canonical mapping. Two important specifics:

• Speaking — your microphone audio is uploaded only when you press Record. The audio is transcribed (via the OpenAI Whisper API) and analysed for pronunciation and fluency, then stored in your private Speaking history. You can delete any recording from the Speaking page at any time.
• Reading & Writing — passages and essays are sent to our AI grader purely to produce a response (corrections, comprehension feedback, exam scoring). Neither the prompt nor the response is used to train external models.

8. Sharing & sub-processors

We share your data only in these specific cases:

• You explicitly publish or share a passage, submission, or speaking attempt via a "Share" button — that creates a public, opt-in URL you control and can revoke at any time.
• Sub-processors we depend on, named below.
• Legal compliance — if compelled by valid legal process, we may disclose data necessary to comply, but we will resist over-broad requests where lawful.
• Business transfer — if LinguaDig is acquired or merged, your data would transfer to the successor under the same terms; you would be notified before any change takes effect.

We do not sell, rent, or trade your personal data — under any circumstance.

Sub-processor list (GDPR Art. 28)

The following independent service providers process specific data on our behalf, under written Data Processing Agreements requiring confidentiality, security, and EU-aligned safeguards. Adding or removing a row here is a substantive policy change — you'll be asked to review the updated policy before continuing to use uploads.

9. International transfers

LinguaDig is operated globally. Most of our sub-processors are based in the United States. When your data leaves the European Economic Area or the United Kingdom, we rely on the European Commission's Standard Contractual Clauses (Module Two: controller-to-processor) with each sub-processor. The UK addendum to the SCCs is appended for UK-resident users.

Where a sub-processor is certified under the EU-US Data Privacy Framework, we additionally rely on that certification as a complementary transfer mechanism. Either mechanism, on its own, is sufficient.

You can request a copy of the relevant SCCs by emailing dpo@linguadig.app.

10. Retention periods

The retention column in §2 is the authoritative rule per category. In summary:

• Account data & learning content: kept for the lifetime of your account; on deletion, purged within 30 days.
• Voice biometrics: deletable any time; auto-purged 30 days after account deletion.
• Subscription & payment records: retained 7 years for tax/accounting compliance.
• Usage analytics: 24 months in event-level form, then aggregated.
• Security logs: 90 days standard; longer only during an active investigation.
• Support tickets & attachments: ticket lifetime + 90 days, then purged.

If a third party files a valid takedown notice against content you uploaded, we keep a hash of the removed content (not the content itself) to prevent re-upload. This is industry-standard practice for DMCA / EU DSA compliance and is documented in our Terms §10.

11. Your rights

You have the following rights over your personal data, available directly from the app — no support ticket required:

• Right of access (GDPR Art. 15) — view your profile, preferences, and content from Profile.
• Right to rectification (Art. 16) — edit your profile or any submission directly.
• Right to erasure (Art. 17, "right to be forgotten") — delete individual rows, reset all learning content, or fully delete your account from Profile → Danger zone. We action erasure within 30 days.
• Right to data portability (Art. 20) — export your data as JSON, or export your flashcards as an Anki deck, from Profile → Export.
• Right to restrict processing (Art. 18) — pause specific processing (e.g. AI analysis) by contacting dpo@linguadig.app.
• Right to object (Art. 21) — object to processing based on legitimate interest at any time.
• Right not to be subject to automated decisions (Art. 22) — none of our processing produces legal or similarly significant effects on you.
• Right to withdraw consent (Art. 7(3)) — for any processing based on consent, withdrawal is one click and takes effect immediately. Withdrawal does not affect prior lawful processing.
• Right to lodge a complaint — EU residents may complain to their national supervisory authority; UK residents to the Information Commissioner's Office (ico.org.uk).

12. Cookies & tracking

We use only the minimum cookies required to keep you logged in and to remember your in-app preferences (e.g. language, theme). We do not embed third-party advertising trackers, social-media pixels, or cross-site behavioural cookies.

Aggregated, anonymised analytics events are recorded server-side to understand which features are used most. These events are not linked to your account profile and are not shared with any analytics vendor.

Because we use no advertising or third-party tracking cookies, no separate cookie consent banner is required under the ePrivacy Directive. If we ever introduce one we will publish a banner and update this policy first.

13. Children

LinguaDig is not directed at children. We adopt the strictest applicable threshold globally: users must be at least 16 to create an account. (Some jurisdictions, including the United States under COPPA, set the floor at 13; the European default under GDPR Art. 8 is 16; we apply 16 to everyone for simplicity.)

We do not knowingly collect personal information from anyone under 16. If you believe a child has registered without parental consent, contact dpo@linguadig.app and we will remove the account within 7 days.

14. California (CCPA / CPRA)

If you are a California resident, the California Consumer Privacy Act (as amended by the CPRA) gives you specific rights. We honour these rights for all users globally; this section restates them in the language California requires.

Categories of personal information collected (last 12 months)

• Identifiers: name, email, IP address.
• Customer records: profile photo, native language.
• Internet activity: usage events, anonymised analytics.
• Audio / electronic information: speaking recordings, voice clones (with separate explicit consent).
• Inferences: CEFR estimate, weak-phoneme inferences, recommended next content.
• Sensitive personal information: voice biometrics (only with explicit consent at the voice-clone surface).

Your CCPA / CPRA rights

• Right to know what personal information we collect, use, disclose, and "share" — covered above and in §2.
• Right to delete your personal information — available from Profile → Danger zone.
• Right to correct inaccurate personal information — edit from Profile.
• Right to opt out of "sale" or "sharing" — we do not sell or share your personal information for cross-context behavioural advertising. There is therefore nothing to opt out of, but to be unambiguous you can confirm this status from Profile → Privacy controls. We honour the Global Privacy Control (GPC) signal as an opt-out.
• Right to limit use of sensitive personal information — you can revoke voice-biometric processing at any time by deleting your voice clone. We do not use sensitive PI for inferring characteristics about you.
• Right to non-discrimination — exercising any of these rights will not affect the price, level, or quality of the service.
• Authorised agents — you may designate an authorised agent to make a request on your behalf; we will verify the agent's authority. Email privacy@linguadig.app.

The 12-month "shared/disclosed" disclosure: in the past 12 months we have not sold or "shared" personal information; we have disclosed personal information only to the sub-processors named in §8, for the operational purposes named there.

15. Changes to this policy

We may update this Privacy Policy as the platform evolves. Each version is immutable once published; substantive changes ship as a new version with a new effective date and bumped version number.

• Patch changes (typo, link fix, no change in legal meaning) — published silently; no re-agreement required.
• Substantive changes — surfaced via an in-app banner before they take effect, with a 14-day review window for EU/UK residents. You'll be asked to review and re-agree before your next upload.
• The changelog of every published version is available on request (dpo@linguadig.app).

16. Contact & DPO

Questions, requests, or concerns about this policy? You have a few options:

• Privacy / DPO contact: dpo@linguadig.app (EU GDPR Art. 38 contact).
• General privacy inbox: privacy@linguadig.app.
• In-app: the Support page — we typically respond within one business day.

Effective date: 2026-05-05 · Version: 2026-05-v1.0