Privacy Policy - Lingotify

1. Introduction

Offbeat Tech ("we," "us," "our," or "Company") operates the Lingotify application (the "Application"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application and website.

Lingotify is a language learning platform that combines artificial intelligence with music to help users learn languages more effectively. We are committed to protecting your privacy and ensuring transparency about our data practices, including compliance with the General Data Protection Regulation (GDPR), the Children's Online Privacy Protection Act (COPPA), and other applicable privacy laws.

Please read this Privacy Policy carefully. If you do not agree with our policies and practices, please do not use our Application. Your continued use of the Application following the posting of revised Privacy Policy means that you accept and agree to the changes.

2. Information We Collect

A. Information You Provide Directly

Account Registration: Email address (required for account creation)
Profile Information: Name (optional), profile picture, language preferences, learning goals
Payment Information: Processed securely through RevenueCat; we do not store full credit card details
Communications: When you contact us for support, feedback, or inquiries, we collect the content of your messages
User-Generated Content: Learning notes, custom vocabulary lists, saved songs, and progress annotations

B. Information Collected Automatically

Device Information: Device type, operating system version, device identifier, mobile network information
Usage Analytics: Features accessed, time spent on lessons, completion rates, interaction patterns
Learning Progress: Lessons completed, vocabulary learned, test scores, learning streaks
Network Information: IP address, connection type (WiFi/cellular)
App Performance: Crash reports and error logs (collected through Sentry)
Cookies and Similar Technologies: On our website, we use cookies to enhance user experience and track aggregated analytics

We do not collect precise geolocation data. We may collect approximate location information at the country or region level for service optimization and analytics purposes.

3. How We Use Your Information

We use the information we collect for the following purposes:

Account Management: Creating and managing your account, authentication, and password recovery
Service Delivery: Providing language learning features, personalized learning recommendations, and customized content
AI-Powered Features: Generating vocabulary, creating personalized songs, and providing translations
Quality Improvement: Analyzing user behavior to improve features, fix bugs, and optimize performance
Communication: Sending service updates, security alerts, promotional materials (with your consent), and customer support responses
Legal Compliance: Fulfilling legal obligations, enforcing terms of service, and protecting rights and safety
Analytics: Understanding usage patterns to improve the Application (aggregated and anonymized data)
Fraud Prevention: Detecting and preventing fraudulent activities, abuse, and security threats

4. AI Features and Data Processing

Lingotify uses artificial intelligence technologies to deliver personalized language learning experiences. We maintain strict policies regarding how data is processed by AI services:

A. Music Generation (Suno AI)

When you create a personalized song, we send your selected vocabulary words and learning preferences to Suno's API. We do not share personal data such as your name, email address, or account information. The data processed is limited to the specific vocabulary and preferences needed for music generation.

B. Vocabulary and Content Generation (Google Gemini / OpenAI)

For vocabulary generation and educational content creation, we may use AI language models. We transmit topic preferences and learning level information, but no personally identifiable information (such as name or email) is included in these requests.

C. Translation Services (Google Translate, DeepL, Lingva)

Words and phrases are sent to translation APIs for accurate translations. User identity information is not included in translation requests. Translation data is processed according to each provider's privacy policy.

D. Your Rights Regarding AI Processing

AI features are only activated by your explicit action (e.g., clicking "Generate Song")
Core language learning features function without AI generation
AI processing is never used for advertising or behavioral profiling
You may delete AI-generated content through your account settings
You have the right to request information about how your data is processed by AI services

Third-Party AI Provider Links:

5. Third-Party Services and Data Sharing

We work with carefully selected third-party service providers to enhance the Lingotify experience. These providers are contractually obligated to use your information only as necessary to provide services to us and maintain the confidentiality and security of your data.

A. Essential Service Providers

Supabase: Database and authentication services. Your account credentials, profile data, and learning progress are stored in Supabase Cloud infrastructure.
RevenueCat: In-app purchase management. Handles subscription and premium feature transactions without storing full payment card details.
Sentry: Error tracking and crash reporting. Helps us identify and fix technical issues. Organization ID: offbeat-tech.
Google Play Services: Required for Android app functionality, authentication, and app safety features.

B. Optional Analytics Service

PostHog: Optional analytics platform. Users may opt-in to enhanced analytics. No personal data is shared with PostHog; only anonymized usage patterns are tracked.

C. Data Sharing Principles

We share only the minimum necessary data required for each service to function
No personal data is shared with AI music or content generation services
Third-party services are prohibited from using your data for their own marketing purposes
We require all third parties to maintain industry-standard security measures
We may disclose information when required by law, court order, or governmental request

6. Data Storage, Security, and International Data Transfers

A. Where Your Data Is Stored

Your personal data is primarily stored in Supabase Cloud infrastructure. Supabase operates data centers in multiple geographic regions. Depending on your account settings and service selection, your data may be stored in Europe, North America, or Asia-Pacific regions.

B. Security Measures

We implement comprehensive security measures to protect your personal information:

End-to-end encryption for sensitive data in transit (TLS/SSL protocols)
Encryption at rest for stored personal data
Role-based access controls limiting employee access to personal information
Regular security audits and penetration testing
Two-factor authentication available for account protection
Compliance with OWASP Top 10 security standards
Incident response procedures for potential data breaches

C. International Data Transfers

As an application available globally, your personal data may be transferred to, stored in, and processed in countries other than your country of residence. These countries may have data protection laws that differ from your home country. By using Lingotify, you consent to the transfer of your information to countries outside your country of residence, including the United States, which may provide a different level of data protection than your home country.

For EU/EEA residents, we rely on appropriate safeguards for international transfers, including Standard Contractual Clauses (SCCs) and adequacy decisions where applicable. For transfers involving Supabase and third-party services, we ensure compliance with GDPR Chapter V requirements.

Governing Law: This Privacy Policy and any data processing matters are governed by the laws of the Republic of Turkey. Any disputes shall be subject to the jurisdiction of the Istanbul courts.

7. Children's Privacy (COPPA Compliance)

Lingotify is not intended for children under 13 years of age, and we do not knowingly collect personal information from children under 13. We comply fully with the Children's Online Privacy Protection Act (COPPA).

A. Age Restriction

Users must be at least 13 years old to create an account
By creating an account, you represent that you are at least 13 years old
We do not knowingly solicit or collect personal information from users under 13

B. If We Discover a Child Account

If we discover that a user under 13 has provided personal information to Lingotify, we will:

Immediately delete all personal information associated with that account
Provide notice to the parent or guardian if contact information is available
Not use the collected information for any purpose

If you are a parent or guardian and believe your child has created an account or provided personal information to Lingotify, please contact us immediately at legal@lingotify.app with proof of parental relationship.

C. Additional Protections for Young Users (13-18)

For users aged 13-17, we provide additional privacy protections:

Account data is not shared with third-party advertisers
AI processing is limited to core educational features only
Marketing communications require explicit opt-in
Parents may request data deletion on behalf of minor children

8. Your Privacy Rights

A. GDPR Rights (For EU/EEA Residents)

Under the General Data Protection Regulation (GDPR), EU and EEA residents have the following rights:

Right to Access: You may request access to the personal data we hold about you
Right to Rectification: You may request correction of inaccurate or incomplete personal data
Right to Erasure ("Right to be Forgotten"): You may request deletion of your personal data, subject to certain exceptions
Right to Restrict Processing: You may request that we limit how we process your data
Right to Data Portability: You may request your data in a structured, commonly-used, machine-readable format
Right to Object: You may object to processing of your data for marketing or profiling purposes
Right to Withdraw Consent: You may withdraw consent for data processing at any time
Right to Lodge a Complaint: You may file a complaint with your local data protection authority

B. General User Rights (All Jurisdictions)

Data Access: You can view your account information and learning progress at any time within the app
Data Correction: You may update your profile information directly within your account settings
Data Deletion: You may request deletion of your account and associated personal data
Marketing Opt-Out: You may unsubscribe from promotional emails at any time via the unsubscribe link or account settings
Analytics Opt-Out: You may disable optional analytics (PostHog) in your account preferences

C. How to Exercise Your Rights

To exercise any of these rights, please contact us using the contact information below:

Email: legal@lingotify.app
In-App Request: Use the "Data Privacy Request" feature in Account Settings

We will respond to all requests within 30 days. If your request involves complex data retrieval or multiple records, we may extend this timeline to 60 days, and we will notify you of the extension.

D. Account Deletion

You may delete your Lingotify account at any time through the app settings or by emailing support@lingotify.app. Account deletion will:

Permanently remove your account credentials and profile information
Delete your learning progress, vocabulary lists, and saved content within 30 days
Remove your email from our marketing communications list
Not affect data already anonymized or aggregated for analytics purposes

9. Data Retention Policy

We retain your personal data for different periods depending on the type of information and how it is used:

Account Data: Retained while your account is active and for 90 days after account deletion, then permanently deleted
Learning Progress: Retained for the duration of your account use; deleted 30 days after account closure
Payment Information: Retained by RevenueCat according to their policies; credit card data is never stored by Lingotify
Support Communications: Retained for 2 years to assist with customer service inquiries
Error Logs (Sentry): Retained for 90 days for debugging purposes
Aggregated Analytics: Retained indefinitely for improvement and research purposes (anonymized and cannot identify individuals)
Marketing Communications: Deleted immediately upon unsubscribe request

If we are required to retain data by law, we will retain it for the legally required period even if you request deletion.

10. Cookies and Similar Technologies (Web Version)

Our website uses cookies and similar tracking technologies to enhance user experience, remember preferences, and analyze usage patterns.

A. Types of Cookies We Use

Essential Cookies: Required for website functionality (login sessions, security)
Preference Cookies: Remember your language choice and display preferences
Analytics Cookies: Track aggregate usage to improve website performance
Marketing Cookies: May be used if you have opted into promotional communications

B. Cookie Management

You can control cookies through your browser settings. Most browsers allow you to refuse cookies or alert you when cookies are being sent. However, disabling cookies may affect website functionality. For more information on cookie management, visit allaboutcookies.org.

11. Changes to This Privacy Policy

Lingotify may update this Privacy Policy from time to time to reflect changes in our data practices, technology, legal requirements, or other factors. We will notify you of material changes by:

Updating the "Last updated" date at the top of this policy
Posting a prominent notice in the app announcing significant changes
Sending an email notification for major privacy practice changes affecting your data

Your continued use of Lingotify following the posting of revised Privacy Policy means that you accept and agree to the changes. We recommend reviewing this policy periodically to stay informed about how we protect your information.

12. Contact Us

If you have questions about this Privacy Policy, concerns about our data practices, or wish to exercise your privacy rights, please contact us:

For General Support: support@lingotify.app
For Privacy Requests & Legal Matters: legal@lingotify.app
Company: Offbeat Tech
Website: https://lingotify.app

We will respond to all inquiries within 10 business days. If you are not satisfied with our response, you have the right to lodge a complaint with your local data protection authority.

This Privacy Policy is effective as of February 2026 and replaces all previous versions. Thank you for trusting Lingotify with your language learning journey.