Privacy policy

Last updated: [date]

Lingua is a service for practising spoken Italian and English with an AI conversation partner. This policy explains what personal data we collect, why, who receives it, and the rights you have under the EU General Data Protection Regulation (GDPR).

Who is responsible for your data

What we collect

• Account data: your email address and a hashed password. We never store your password in readable form.
• Usage and plan data: your remaining minutes, your plan or licence and its expiry date, and the start and end times of your practice sessions.
• Payment data: payments are handled by Stripe. We receive your email, the plan you bought and the payment status. We never see or store your card number.
• Voice and conversation: when you talk, your voice is streamed live to Google's Gemini service to produce the replies. We do not record or store your audio. The chat text shown on screen stays in your browser and is not saved on our servers.
• Technical data: your IP address and basic request logs, used for security and to limit abuse.
• Emails we send you: we keep a log of account and payment emails (such as verification and password reset messages) to show that they were sent.

Why we use it, and on what basis

• To create your account and provide the service, including counting your minutes: performance of our contract with you.
• To process payments and keep accounting records: performance of the contract and legal obligations.
• To keep the service secure and prevent abuse or account sharing: our legitimate interest.
• To send you marketing messages, if we ever do: only with your separate consent, which you can withdraw at any time.

Who receives your data

We use these providers to run the service. Each only receives what it needs.

• Stripe, for payments.
• Google (Gemini API), which processes your live voice during a session. If you use your own Gemini key, your voice goes from your browser directly to Google under your own Google account and terms.
• [Render, Frankfurt region], for hosting the website and application.
• [Neon / Render Postgres / your server], for storing account data.
• [Your email provider], for sending account emails.

Some of these providers are based in, or may process data in, countries outside the European Economic Area, such as the United States. Where this happens, transfers rely on safeguards such as the EU-US Data Privacy Framework or standard contractual clauses. [Confirm the mechanism each provider uses.] We do not sell your data.

How long we keep it

• Account data: until you delete your account or ask us to.
• Payment and invoice records: for the period the law requires for accounting and tax [state period].
• Technical and email logs: [for example 6 months], then deleted.

Your rights

You can ask us to give you a copy of your data, correct it, delete it, restrict or object to its use, or send it to you in a portable format. You can withdraw any consent at any time. Write to [privacy@yourdomain.com] and we will answer within one month. You also have the right to complain to the Italian data protection authority, the Garante per la protezione dei dati personali (garanteprivacy.it).

Cookies and local storage

We use your browser's local storage to keep you signed in and, if you choose to use your own Gemini key, to remember that key on your device only. Both are strictly necessary for the service to work. We do not use advertising or tracking cookies. If this changes, we will ask for your consent first.

Security

Connections use HTTPS, passwords are stored hashed, sign-in attempts are rate limited, and access to our systems is restricted. No system is perfectly secure. If a breach affects your rights, we will notify you and the authorities as the law requires.

Children

Lingua is not intended for children under [16]. If you believe a child has created an account, contact us and we will delete it.

Changes to this policy

If we change this policy in a meaningful way, we will update the date above and tell you by email or in the app.