This Privacy Policy explains how Stark Husky Platforms, a company incorporated under the laws of the Republic of Panama ("ConMigo," "we," "us," or "our") collects, uses, stores, and protects your personal information when you use the ConMigo mobile application and related services. Please read this policy carefully.
1. Who We Are
ConMigo is a Spanish language learning application operated by Stark Husky Platforms, a company incorporated under the laws of the Republic of Panama. Our registered address is Republic of Panama. For privacy-related inquiries, you may contact us at contact@learnconmigo.app.
2. Information We Collect
2.1 Information You Provide Directly
- Account registration data: your name, email address, and password when you create an account.
- Profile information: your learning goals, experience level, and language preferences you provide during onboarding.
- Payment information: if you subscribe to ConMigo Pro, payment is processed by third-party providers (Apple App Store or Google Play). We do not store your credit card or payment details directly.
- Communications: if you contact us for support, we collect the content of your messages.
2.2 Information Collected Automatically
- Learning data: your lesson completion status, quiz responses, error rates, vocabulary scores, grammar results, and Repaso Engine activation events. This data is essential to deliver the adaptive learning experience.
- Speech data: when you use the Habla con Migo speech recognition feature, audio is processed on-device via your device's speech recognition system (expo-speech-recognition). We do not store raw audio recordings on our servers.
- Usage data: features accessed, screens viewed, session duration, and interaction patterns within the app.
- Device data: device type, operating system version, app version, device identifier, and crash/error logs.
- Technical data: IP address (for authentication and security purposes), time zone, and language settings.
2.3 Information from Third Parties
- AI conversation data: when you engage in Habla con Migo conversations, text is processed by Google Gemini API. Please refer to Google's privacy policy for information on how Google handles API data.
- Authentication data: if you sign in via third-party providers (e.g., Apple Sign In or Google Sign In), we receive a unique identifier and, where permitted, your name and email address.
3. How We Use Your Information
We use the information we collect for the following purposes:
3.1 To Provide and Improve the Service
- Deliver personalized Spanish lessons, vocabulary exercises, and grammar instruction.
- Operate the Repaso Engine: calculate your error rate, trigger adaptive remediation lessons, and track your progression through curriculum units.
- Generate AI-powered conversation practice through Habla con Migo, constrained to your current vocabulary knowledge.
- Maintain your learning progress, unit completion status, and Knowledge Bank history.
- Provide customer support and respond to your inquiries.
- Improve the accuracy and effectiveness of our curriculum, AI responses, and remediation system.
3.2 For Account and Subscription Management
- Create and manage your user account.
- Process subscription payments and manage Pro tier access.
- Send transactional emails: account confirmation, password reset, subscription receipts, and service notices.
3.3 For Safety and Legal Compliance
- Detect and prevent fraud, abuse, or unauthorized access to our systems.
- Comply with applicable laws, legal processes, and regulatory requirements.
- Enforce our Terms of Service.
3.4 Analytics and Product Development
- Analyze aggregate, anonymized usage patterns to understand how learners progress through the curriculum.
- Measure the effectiveness of the Repaso Engine and other adaptive features.
We do not sell your personal data to third parties. We do not use your personal data for advertising profiling.
4. Legal Basis for Processing (GDPR / International Users)
If you are located in the European Economic Area (EEA), United Kingdom, or other jurisdictions with similar data protection laws, our legal basis for processing your personal data is:
- Contract performance: processing necessary to deliver the ConMigo service you have signed up for.
- Legitimate interests: improving our product, preventing fraud, and ensuring security.
- Consent: for optional features such as marketing communications, which you may withdraw at any time.
- Legal obligation: where processing is required to comply with applicable law.
5. How We Share Your Information
We share your information only in the following limited circumstances:
5.1 Service Providers
We work with trusted third-party service providers who process data on our behalf, under contractual obligations of confidentiality and data protection:
- Supabase (database and authentication infrastructure)
- Google Gemini API (AI conversation processing)
- Apple App Store and Google Play (payment processing and app distribution)
- Expo / React Native infrastructure providers
5.2 Legal Requirements
We may disclose your information if required to do so by law, court order, or governmental authority, or if we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, or investigate fraud.
5.3 Business Transfers
If ConMigo is involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you via email or prominent in-app notice before your data is transferred and becomes subject to a different privacy policy.
5.4 University and Institutional Pilots
If your access to ConMigo is provided through a university or institutional pilot program, your progress data (unit completion, error rates, Repaso activations) may be shared with the relevant institution's authorized instructors in anonymized or identified form, as agreed in the pilot agreement. You will be informed of this at the time of enrollment.
6. Data Retention
We retain your personal data for as long as your account is active or as needed to provide our services. Specifically:
- Account and learning data: retained for the duration of your account, plus 24 months after account deletion for legal and dispute resolution purposes.
- Payment records: retained for 7 years as required by applicable tax and financial regulations.
- Support communications: retained for 2 years.
- Anonymized usage analytics: retained indefinitely in aggregated, non-identifiable form.
You may request deletion of your personal data at any time. See Section 8 (Your Rights) for details.
7. Data Security
We implement industry-standard security measures to protect your personal information, including:
- Encryption of data in transit (TLS/HTTPS) and at rest.
- Access controls limiting employee access to personal data on a need-to-know basis.
- Secure authentication via Supabase, including support for two-factor authentication.
- Regular security reviews of our infrastructure and third-party integrations.
No method of electronic transmission or storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee absolute security. In the event of a data breach that affects your rights and freedoms, we will notify you as required by applicable law.
8. Your Rights
Depending on your location, you may have the following rights regarding your personal data:
- Access: request a copy of the personal data we hold about you.
- Correction: request correction of inaccurate or incomplete data.
- Deletion: request deletion of your personal data ("right to be forgotten"), subject to legal retention obligations.
- Portability: request your learning data in a structured, machine-readable format.
- Restriction: request that we restrict processing of your data in certain circumstances.
- Objection: object to processing based on our legitimate interests.
- Withdrawal of consent: where processing is based on consent, withdraw it at any time without affecting prior processing.
To exercise any of these rights, contact us at contact@learnconmigo.app. We will respond within 30 days. For account deletion, you may also use the "Delete Account" option within the app settings.
9. Children's Privacy
ConMigo is not directed to children under the age of 13 (or 16 in the EEA). We do not knowingly collect personal information from children under these ages. If you are a parent or guardian and believe your child has provided us with personal information, please contact us at contact@learnconmigo.app and we will delete the information promptly.
For users between 13 and 18 years of age, we recommend parental supervision. Certain features (including subscription purchases) may require parental consent depending on your jurisdiction.
10. International Data Transfers
ConMigo is operated from the Republic of Panama. Our service providers, including Supabase and Google, may process your data in the United States and other countries. When we transfer personal data internationally, we rely on appropriate safeguards including standard contractual clauses and the data processing terms of our service providers. By using ConMigo, you acknowledge that your data may be transferred to and processed in countries outside your country of residence.
11. Cookies and Tracking
The ConMigo mobile application does not use browser cookies. We use device-based identifiers and local storage for session management and app state persistence. We do not use third-party advertising trackers or behavioral advertising SDKs in our application.
12. Third-Party Links and Services
The app may contain links to third-party websites or services (such as App Store pages or support resources). This Privacy Policy does not apply to those third parties. We encourage you to review the privacy policies of any third-party services you access through ConMigo.
13. Changes to This Policy
We may update this Privacy Policy from time to time. When we make material changes, we will notify you by email (to the address associated with your account) and/or via a prominent notice within the app at least 14 days before the change takes effect. Your continued use of ConMigo after the effective date of the revised policy constitutes your acceptance of the changes.
The current version of this policy is always available at: https://www.learnconmigo.app/privacy
14. Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:
ConMigo Privacy Team
Stark Husky Platforms, a company incorporated under the laws of the Republic of Panama
Republic of Panama
Email: contact@learnconmigo.app
Website: https://www.learnconmigo.app