Privacy Policy

1. Data we collect

• Account data — your email address and a securely hashed password (we never store your actual password).
• Profile data — display name, profile picture (if provided), Spanish dialect preference, CEFR level, your reason for learning, any free text you write describing your learning goal, target date, and daily time goal.
• Subscription and payment data — your subscription status and plan, and a reference used to link your account to whichever payment provider processed your subscription:
  • If you subscribed via our website, this is a customer reference ID with Stripe, our web payment processor.
  • If you subscribed via the iOS app, this is handled by Apple through In-App Purchase — Apple manages your payment method and billing directly; we receive only your subscription status and a reference confirming the purchase, via Apple's server-to-server notifications.
  • In neither case do we store your card details or billing address ourselves — these are held entirely by Stripe or Apple respectively.
  • We record which payment method was used (web/Stripe or iOS app/Apple) for our own internal accounting — this doesn't affect how your account works and access to the app is the same regardless of which you used.
• Usage data — lessons completed, flashcard and quiz scores, streaks, experience points, and related learning-progress timestamps, linked to your account so your progress is saved.
• Voice recordings (Speaking practice) — see Section 4 for how these are handled.
• Product analytics — pseudonymous event data about which features of the app are used and how often, analysed in aggregate (e.g. which lessons or games are opened, and whether usage patterns differ between web and the iOS app). See Section 7 for detail on how this is handled.
• Technical data — your IP address may be temporarily logged (retained up to 30 days) against specific API requests for abuse-prevention purposes (see Section 8).
• Communications — any support emails you send us.

We do not knowingly collect any data from, or aimed at, children under 13. We do not collect special category (sensitive) data. We do not make any decisions about you using solely automated means that would have a legal or similarly significant effect on you.

2. How we use your data

• To personalise your lessons and track your learning progress.
• To manage your account and subscription.
• To send essential transactional emails (e.g. signup confirmation, billing).
• To improve Rumbo, using pseudonymous event data analysed in aggregate.
• To respond to support requests.
• To prevent abuse of our systems (see Section 8).
• To meet our legal and tax obligations.

3. Legal basis for processing

We rely on: Contract(to provide the service you've signed up for); Legitimate interests (product improvement and fraud/abuse prevention); Legal obligation (tax and financial record-keeping); and Consent (for analytics and advertising cookies, and for sharing hashed purchase data with Meta for ad measurement on web purchases — see Section 7).

4. Who we share data with

We do not sell, rent, or trade your personal data. We share it only with the following service providers, each acting under their own data protection terms:

• Supabase — our database and authentication provider. Data is hosted in Ireland (EU — AWS eu-west-1).
• Stripe — payment processing for web subscriptions. PCI-DSS compliant; we never see or store your full card details or billing address. We pass your unique account ID to Stripe so payments can be matched to your account. Their privacy policy is available at stripe.com/gb/privacy.
• Apple — payment processing for iOS app subscriptions, via In-App Purchase. Apple manages your payment method, billing, and receipt directly; we receive subscription status updates via Apple's server notifications, matched to your account by reference ID only. Apple's privacy policy is available at apple.com/legal/privacy.
• Anthropic — powers our AI-generated lessons, conversation practice, and the marking of your Speaking and Writing practice, hosted in the United States. Lesson prompts include your CEFR level and learning goal. For marking, the text of your writing submission or the transcript of your speaking recording is also sent. We never send your name or email. Under Anthropic's commercial terms of service, this data is not used to train its models.
• ElevenLabs — when you use Speaking practice, your voice recording is sent to ElevenLabs to be converted to text. We do not store the audio recording ourselves; we keep the resulting transcript so we can mark your practice and show your progress. ElevenLabs processes the recording under its own terms and privacy policy, and may retain it for a limited period.
• PostHog — our product analytics provider, used to understand in aggregate how the app itself is used, hosted in the EU. This tracking is pseudonymous — we don't link it to your name or account, and we don't use it to identify or profile individual users.
• Resend — sends transactional emails (e.g. signup confirmation). They receive your email address only to deliver those emails.
• Vercel — hosts our application; request traffic passes through Vercel's infrastructure in transit.
• Meta — if you accept analytics/advertising cookies on our website (see Section 7), we use the Meta Pixel to measure ad performance on our marketing pages, and, only when you complete a paid subscription via the website, we send Meta a one-way, irreversibly hashed version of your email address so Meta can measure ad conversions. This only applies to web/Stripe purchases — purchases made through the iOS app never trigger this, regardless of any cookie choice made on the website. If you have not accepted cookies, none of this is sent. Note that while the hash itself cannot be reversed to recover your email, Meta may still be able to match it against its own records to associate it with your Meta/Instagram account, so we treat this as personal data and gate it behind your consent accordingly.
• Google — if you accept analytics cookies (see Section 7), we use Google Analytics to understand how visitors use our marketing pages.

We may disclose your data if required by law, court order, or to protect the safety of our users or the public.

5. Data retention

If you ask us to delete your account, we will delete your personal data within 30 days, except where we are required to keep financial records for up to 7 years for tax purposes. To delete your account, email hello@rumbospanish.app and we will action this manually.

Pseudonymous product-analytics data, analysed in aggregate, may be retained longer to help us understand product trends.

6. Your rights

Under UK GDPR you have the following rights. You can exercise any of them by emailing us at hello@rumbospanish.app.

You can contact the UK Information Commissioner's Office (ICO) at ico.org.uk at any time if you believe we have not handled your data correctly; we're also happy to try to resolve concerns directly if you'd prefer.

7. Cookies and tracking

When you first visit Rumbo on the web, we ask whether you're happy for us to use analytics and advertising cookies. Until you make a choice, and unless you choose “Accept”, we do not load Google Analytics or the Meta Pixel, and we do not send the Meta conversion event described in Section 4 — nothing is tracked. You can change your mind at any time by clearing your cookies, which will show the banner again.

If you accept, we use: Google Analytics, to understand how visitors use our site; and the Meta Pixel, to measure the effectiveness of our advertising, plus the hashed-email conversion event described in Section 4, which applies only to purchases made on the website itself.

Product analytics inside the app (web and iOS): separately from the marketing-site cookies above, we use PostHog to understand, in aggregate, how the Rumbo app itself is used — for example, which lessons or features are opened, and how often. This tracking is pseudonymous, as described in Section 4.

The iOS app does not load Google Analytics or the Meta Pixel at all — these remain entirely web-only, regardless of any cookie choice made on the website.

Regardless of your cookie choice, we use one piece of essential local storage to remember your onboarding answers as you move through signup, and a small first-party cookie to remember your cookie choice itself.

8. Abuse prevention and security logging

To protect Rumbo from automated abuse (for example, bots making excessive requests), we may temporarily log the IP address, the specific feature accessed, and the time of certain requests, retained for up to 30 days. This data is used only for abuse prevention and is not linked to your account or used for any other purpose.

9. International data transfers

Some of our service providers process data outside the UK/EU, including Anthropic, Stripe, Resend, and Vercel. Where a provider operates outside the UK/EU without an adequacy decision in place, we rely on Standard Contractual Clauses (SCCs) or an equivalent safeguard to protect your data.

10. Security

• All data in transit is encrypted via HTTPS.
• Passwords are hashed, never stored in plain text.
• Access to your data is restricted by access controls.

11. Changes to this policy

If we make material changes to this policy, we will announce them with an on-page “What changed” note (as above) and, where appropriate, by email to account holders, giving at least 14 days' notice before they take effect.