Privacy Policy

Last updated: April 14, 2026

LingoTouch ("LingoTouch", "we", "our", or "us") is committed to protecting your privacy. This Privacy Policy describes how we collect, use, disclose, and safeguard personal information in connection with the LingoTouch application, websites, and related services (collectively, the "Service"). It applies to all users of the Service, including visitors, registered users, and subscribers, and should be read together with our Terms of Service.

1. Data Controller

LingoTouch acts as the data controller for personal information processed in connection with the Service, except where we process such information on behalf of a school, employer, or other customer (in which case we act as a processor under that customer's instructions).

2. Information We Collect

We collect the following categories of information:

  • Account information you provide, such as name, email address, authentication credentials, profile preferences, and avatar.
  • Learning data generated through your use of the Service, including level progress, vocabulary discovered, accuracy scores, streaks, and session timestamps.
  • Voice recordings and speech data. When you use speaking exercises, we process audio recordings of your voice to assess pronunciation and provide feedback. Recordings may be processed on-device and/or transmitted to our servers and trusted speech-recognition providers.
  • Device and technical information, such as device model, operating system, browser type, language, time zone, IP address, crash logs, and diagnostic data.
  • Usage information, such as screens viewed, features used, referral source, and interaction events, collected through cookies, SDKs, and similar technologies.
  • Transaction information. We do not receive or store your full payment card details. When you subscribe, the relevant app store processes the payment and shares limited information with us, such as subscription status, product identifier, and transaction identifier.
  • Support communications, including messages, survey responses, and any information you choose to send us.

3. How We Use Your Information

We use personal information to:

  • provide, personalize, and improve the Service and learning experience;
  • evaluate pronunciation, generate feedback, and adapt lesson difficulty based on your performance;
  • authenticate users, maintain sessions, and prevent fraud or abuse;
  • process subscriptions, entitlements, and comply with tax and accounting obligations;
  • communicate with you about the Service, including service announcements, security notices, and, with your consent where required, promotional messages;
  • conduct analytics, research, and product development, typically using aggregated or de-identified data;
  • enforce our Terms and comply with applicable laws and lawful requests.

4. Legal Bases for Processing (EEA/UK)

If you are in the European Economic Area, the United Kingdom, or Switzerland, we rely on the following legal bases:

  • Contract — to provide the Service you requested and manage your account and Subscription;
  • Legitimate interests — to secure, analyze, and improve the Service, in a manner proportionate to your privacy rights;
  • Consent — for optional processing such as marketing communications, non-essential cookies, and voice recording where required by local law; you may withdraw consent at any time;
  • Legal obligation — where we are required to process information to comply with applicable law.

5. How We Share Information

We do not sell your personal information. We share information only as described below:

  • Service providers that process data on our behalf under written contracts, including cloud hosting, content delivery, analytics, crash reporting, speech recognition, and customer support.
  • App stores and payment processors (Apple, Google) in connection with subscription purchases and entitlement validation.
  • Legal and safety disclosures when we believe in good faith that disclosure is necessary to comply with law, enforce our Terms, or protect the rights, safety, or property of LingoTouch, our users, or others.
  • Business transfers. If LingoTouch is involved in a merger, acquisition, financing, or sale of assets, your information may be transferred as part of that transaction, subject to standard confidentiality undertakings.
  • With your consent or at your direction.

6. International Data Transfers

Your information may be processed in countries other than the one in which you reside, including countries whose data-protection laws differ from those of your country. Where personal information is transferred from the EEA, the UK, or Switzerland to a country not deemed to provide an adequate level of protection, we take steps to ensure that such transfers are carried out subject to appropriate safeguards required by applicable law, such as the European Commission's Standard Contractual Clauses or the UK International Data Transfer Agreement. You may contact us for further information about the safeguards in place.

7. Data Retention

We retain personal information for as long as necessary to provide the Service, fulfill the purposes described in this Policy, and comply with our legal obligations. The retention period depends on the nature of the information and the purpose for which it is processed; for example, account data is retained while your account is active, and certain records may be kept for a longer period where required by law or to resolve disputes and enforce our agreements. Aggregated or de-identified information that can no longer be associated with you may be retained for statistical purposes. You may request deletion of your personal information in accordance with Section 9.

8. Data Security

We implement reasonable administrative, technical, and organizational measures designed to protect personal information against unauthorized access, disclosure, alteration, or destruction, including encryption of data in transit and access controls commensurate with the sensitivity of the information. No security measure is perfect, and we cannot guarantee absolute security. You are responsible for keeping your account credentials confidential and for notifying us promptly of any suspected unauthorized access.

9. Your Rights and Choices

Depending on your location, you may have the right to access, correct, update, port, or delete your personal information; to object to or restrict certain processing; to withdraw consent; and to lodge a complaint with your local data-protection authority. You may also opt out of marketing communications at any time using the unsubscribe link in the email or by contacting us. To exercise your rights, visit the in-app settings or contact hello@lingotou.ch. We will respond within the time periods required by applicable law (generally within 30 days). We may need to verify your identity before acting on a request.

10. U.S. State Privacy Rights

If you are a resident of California, Colorado, Connecticut, Virginia, or another U.S. state with comprehensive privacy legislation, you have the rights described in Section 9, as well as the right not to be discriminated against for exercising those rights. We do not sell personal information or engage in "sharing" of personal information for cross-context behavioral advertising as those terms are defined under the California Consumer Privacy Act.

11. Children's Privacy

LingoTouch is designed for learners of all ages, including children. Where the Service is directed to or knowingly used by children under the applicable age of digital consent (13 in the United States, 16 in most of the EEA/UK), we collect only information that is reasonably necessary to provide the educational experience and we do not condition participation on the disclosure of more information than is reasonably necessary. We obtain verifiable parental consent where required by the Children's Online Privacy Protection Act (COPPA), the GDPR, and other applicable laws. We do not use children's personal information for targeted advertising or profiling, and we do not sell children's personal information. Parents and guardians may review, delete, or refuse further collection of their child's information by contacting hello@lingotou.ch.

12. Cookies and Similar Technologies

We and our service providers use cookies, local storage, mobile identifiers, and similar technologies to keep you signed in, remember preferences, measure performance, and improve the Service. You can control cookies through your browser or device settings. Where required by law, we request your consent before setting non-essential cookies.

13. Third-Party Links and Services

The Service may contain links to third-party websites or services that are not operated by us. This Policy does not apply to those third parties, and we encourage you to review their privacy policies before providing any personal information.

14. Automated Decision-Making

We use automated systems to evaluate pronunciation, recommend lessons, and detect abuse. These systems do not make decisions that produce legal or similarly significant effects on you. You may contact us to request human review of any learning assessment you believe is inaccurate.

15. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will notify you (for example, through an in-app notice or email) and update the "Last updated" date at the top. Your continued use of the Service after the effective date constitutes your acceptance of the updated Policy.

16. Contact Us

If you have questions, concerns, or complaints about this Privacy Policy or our privacy practices, please contact our privacy team at hello@lingotou.ch. EEA/UK users may also contact their local supervisory authority.