Privacy Policy

Comigo ("Comigo," "we," "us," or "our") provides the Comigo mobile application and related services (collectively, the "App"), a gamified language-learning app. This Privacy Policy explains what information we collect, how and why we use it, who we share it with, how long we keep it, and the choices and rights available to you. It applies to the App, to usecomigo.com, and to any other service that links to this Policy.

Please read this Policy carefully. By creating an account or otherwise using the App, you acknowledge that you have read and understood this Policy. If you do not agree with it, please do not use the App.

1. Who This Policy Applies To and Scope

This Policy covers personal information we collect when you:

• Download, install, or use the App
• Create or log into an account
• Interact with our customer support
• Visit our website at usecomigo.com
• Communicate with us by email or through in-app channels

It does not apply to third-party websites, products, or services that may be linked from the App, which have their own privacy practices.

2. Information We Collect

We collect information in three general ways: information you give us directly, information we collect automatically through your use of the App, and information we receive from third parties (such as an identity provider you choose to sign in with).

2.1 Information you provide directly

• Account and identity information: depending on how you choose to sign in, we may collect your email address, display name, and a profile picture. If you sign in using a third-party identity provider (for example, a "Sign in with Google" option), that provider shares with us the basic profile information you've authorized, such as your name, email, and avatar image; we do not receive your password for that third-party account.
• Subscription and purchase information: the App is offered on a paid subscription basis. When you subscribe, the app store you purchase through (the Apple App Store or Google Play) shares with us confirmation that your subscription is active and its status (for example, active, expired, or cancelled), together with an associated transaction identifier. We do not receive or store your full payment card details, which are handled entirely by the applicable app store.
• Onboarding and personalization information: to tailor lessons to you, we may ask for information such as your approximate age, your native language, the language(s) you want to learn, your self-assessed level, and your learning goals or motivations.
• Profile and customization data: your in-app display name, any avatar or character customization choices you make, and, if you choose, a photo you upload to use as your avatar.
• Voice audio: certain interactive speaking and pronunciation features in the App record and process audio of what you say, captured from your microphone while the feature is active. This audio is sent to the third-party providers named in Section 5 so that they can carry out the live conversation, transcribe your speech, and generate spoken replies. See Section 5 ("Voice and AI-Assisted Features") for exactly what is sent, to whom, and what is and is not retained.
• Practice transcripts: the text transcription of what you say during speaking practice, and the text of the answers you type or speak in a lesson, are collected and processed so we can score your answers, give you feedback, and show you your practice history in the App. These transcripts are stored with your account until you delete them or delete your account (see Section 8).
• App-selection input for the optional focus/lock feature: if you choose to use the App's optional distraction-blocking feature, you select which other apps on your device you want to temporarily restrict access to. See Section 4 ("Optional Focus/App-Lock Feature") for details.
• Content you submit: any messages, feedback, support requests, survey responses, or other content you choose to send us.
• Communications: when you contact us (for example by email), we keep a record of that correspondence, including your contact details and the content of the message, so we can respond to you and maintain a record of the interaction.

2.2 Information collected automatically

• Usage and product analytics: we use analytics technology to understand how the App is used in aggregate, for example which features and screens are most used, how often lessons are completed, retention and engagement patterns, and where users encounter friction or errors. This helps us prioritize fixes and improvements.
• Session and interaction recordings: we may use technology that records anonymized playback of in-app interactions to help us diagnose usability issues. Where this is used, personal content such as text you type and images on screen is automatically masked or obscured in any recording, so we do not see the literal content of what you typed or any photo you viewed.
• Device and diagnostic information: standard technical information such as device model, operating system and version, app version, language and locale settings, and crash or error logs, used to keep the App stable and compatible with your device.
• Gameplay and learning-progress data: information generated through your use of the App's features, such as lesson and exercise completion, scores, streaks, in-app rewards earned and spent, saved vocabulary, and achievements/badges unlocked.
• Approximate, non-precise location information may be inferred from your IP address or device locale solely for purposes such as language/region defaults and fraud prevention. We do not collect GPS or other precise location data.

2.3 Information we deliberately do not collect

We have designed the App to avoid collecting categories of sensitive information it does not need to function. We do not request or access your device contacts, calendar, precise/background location, biometric identifiers (such as fingerprint or facial-geometry data used for authentication), call logs, SMS messages, or the content of other apps on your device.

3. Permissions the App May Request

Native mobile operating systems require apps to ask for your permission before accessing certain device capabilities. The App requests only the permissions needed for the specific features below, only at the moment those features are used or set up, and never accesses these capabilities silently or for any purpose other than the feature described.

We do not request camera access, contacts, calendar, precise location, or biometric authentication permissions. Where a mobile platform's policies restrict certain broad permissions, we configure the App to request the narrowest permission available for the feature involved.

4. Optional Focus/App-Lock Feature

The App offers an optional, opt-in productivity feature that lets you temporarily restrict your own access to other apps on your device that you find distracting, until you complete a short learning challenge within Comigo. This feature is entirely under your control: it is off by default, only applies to apps you personally choose, and can be turned off or uninstalled at any time. We explain below, separately for each platform, exactly how it works and what information it involves, because each platform uses a different underlying system capability.

4.1 On Android: Accessibility Service permission

If you choose to enable this feature on Android, the App will ask you to grant it Android's "Accessibility Service" permission. We use this permission solely to detect which app is currently in the foreground on your device (i.e., the package name of the app you just opened), so that we can recognize when you have opened one of the specific apps you previously selected to restrict, and show you Comigo's challenge screen instead.

Importantly:

• The service is configured so that it cannot and does not read the on-screen content, text, or activity of any app (technically, "window content retrieval" is disabled for this service). It can only see which app has come to the foreground, not what you are doing inside it.
• It does not capture keystrokes, screenshots, clipboard contents, passwords, or any other data from other apps.
• It is never used for advertising, profiling, or any purpose other than recognizing the specific, user-selected apps you've asked Comigo to help you avoid.
• It takes no action, and collects no information, with respect to any app you have not explicitly selected.
• You can revoke this permission at any time from your device's Accessibility settings, which immediately disables the feature.

4.2 On iOS: Screen Time (Family Controls) permission

If you choose to enable this feature on iOS, the App uses Apple's built-in Screen Time / Family Controls system, the same underlying system Apple provides for parental controls and personal screen-time management. You select the specific apps you want to restrict using Apple's own app-picker interface. Apple's system, not Comigo, then "shields" those apps; when you try to open one, Apple's operating system displays Comigo's custom screen with a short English challenge.

Importantly:

• Apple deliberately does not reveal to us which specific apps you selected; we only receive anonymous, opaque references to your selection from Apple's system, which we cannot reverse into actual app names or icons.
• We have no visibility into your usage of those apps beyond the moment Apple's system asks us to display our challenge screen.
• Completing the in-app challenge correctly unlocks the selected app(s) for a duration you choose; Apple's system automatically re-applies the restriction afterward.
• You can remove this feature's permission at any time in your device's Screen Time settings, which immediately disables the feature.

4.3 What we store for this feature

We store, locally on your device and/or associated with your account, only what is necessary to operate the feature: which platform-level selection you made (in the limited, non-identifying form described above for iOS, or the app package names you selected for Android), your chosen unlock duration, and your progress through the in-app challenge. We do not use this feature to monitor, log, or report your general device or app usage outside of the narrow mechanism described above.

5. Voice and AI-Assisted Features

Some features of the App, including interactive speaking practice with Capy and the checking of your lesson answers, are powered by third-party artificial intelligence and speech-processing companies that we engage as service providers. This section names those companies and describes exactly what data leaves your device and reaches them.

5.1 What leaves your device

When you use these features, the following information is sent from your device, over an encrypted connection, to the providers named in Section 5.2:

• The audio of what you say into the microphone while a speaking or pronunciation feature is active
• The text transcription of that audio, and the text of the answers you give in a lesson
• The language you are learning
• Your native language
• The practice topic you chose for the conversation

Nothing else about you is sent. In particular, these providers never receive your name, your email address, your contacts, your photos, or your payment details.

5.2 Who receives it

• ElevenLabs, Inc.(United States) powers the live voice conversation, converts your speech to text, and generates Capy's voice. Its privacy policy is available at https://elevenlabs.io/privacy-policy.
• OpenAI, L.L.C. (United States) checks the text of your lesson answers. Its privacy policy is available at https://openai.com/policies/privacy-policy/.

Both companies act as processors on our behalf under data processing terms that require them to provide a level of protection equivalent to the one described in this Policy, to use your data only to deliver the feature to you, and not to use it for their own independent purposes.

5.3 Your permission and how to withdraw it

The App asks for your permission before any of this information is sent, and these features do not run until you give it. You can withdraw that permission at any time in the App under Profile, in the section called "AI and your data". Withdrawing it stops any further sending of your voice audio and practice text to the providers above; the rest of the App continues to work, without the AI-assisted features.

5.4 What we keep

• Raw audio is used only for the duration of the session it belongs to. It is not retained by us after the session ends.
• Text transcripts of your practice sessions and lesson answers are stored with your account until you delete them in the App or delete your account.
• Session metadata (such as the language practiced, the duration of the session, and timestamps) is retained so that we can apply fair-use limits and recognize your practice activity within the App, for example towards streaks or in-app rewards.
• These AI features may occasionally produce imperfect or unexpected output, consistent with the current state of conversational AI technology generally.

6. How We Use Your Information

We use the information described above for purposes including to:

• Create, maintain, and secure your account, and keep your progress synchronized across your devices
• Personalize lessons, difficulty, content recommendations, and pacing
• Operate gamification mechanics such as streaks, in-app rewards, achievements, and customization features
• Deliver features you opt into, such as speaking practice, the optional focus/app-lock feature, and reminder notifications
• Monitor, maintain, debug, and improve the performance, stability, and security of the App
• Understand aggregate usage trends and inform our product roadmap
• Communicate with you about your account, changes to our services, or in response to your inquiries
• Detect, investigate, and prevent fraud, abuse, and security incidents
• Comply with applicable law, respond to lawful requests, and enforce our Terms of Service

We do not sell your personal information to third parties, and we do not use the personal information described in this Policy to serve third-party behavioral advertising within the App.

7. How We Share Information

We do not sell your personal information. We share information only in the following limited circumstances:

• Service providers: we engage trusted third-party companies to perform functions on our behalf, such as cloud database hosting and authentication, cloud infrastructure and file storage, AI-based voice and speech-recognition processing, product analytics, and transactional email delivery (for example, to send sign-in codes). Our AI and speech-processing providers are ElevenLabs, Inc.(United States), which powers the live voice conversation, speech-to-text, and Capy's voice, and OpenAI, L.L.C. (United States), which checks the text of your lesson answers; Section 5 describes exactly what each of them receives. These providers are contractually limited to using your information only to provide services to us and are not permitted to use it for their own independent purposes. Some of these providers may be located, or may process data, outside of your country of residence, including in the United States and within the European Union.
• Identity providers: if you choose to authenticate using a third-party identity provider, basic profile information is exchanged with that provider as part of the sign-in process, governed by that provider's own privacy practices.
• Platform providers: as described in Section 4, the operating-system vendor (Apple or Google) inherently mediates the optional focus/app-lock feature, since it relies on system-level capabilities those platforms provide; our visibility into your selections is limited as described there.
• App stores and refund requests: if you request a refund from the Apple App Store for a purchase made in the App, Apple may ask us for information to help it decide on the request. In that case we, or a service provider acting on our behalf, may share with Apple information about that purchase and your use of the App, such as how long you have had an account, how much you have used the App since the purchase, and your purchase and refund history with us, together with our preference on the request. Apple makes the final decision. By using the App you agree to this sharing.
• Legal and safety reasons: we may disclose information if required to do so by law, regulation, legal process, or governmental request, or where we believe disclosure is necessary to protect the rights, property, or safety of Comigo, our users, or the public, or to detect, prevent, or address fraud, security, or technical issues.
• Business transfers: if we are involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or a portion of our assets, your information may be transferred as part of that transaction. We will notify you of any such change in ownership or control of your personal information.
• With your consent: we may share information for other purposes with your explicit consent.

We do not provide a comprehensive list of our individual sub-processors in this public Policy, but we are happy to provide more detail about a specific provider relevant to your data upon a verified request, where appropriate.

8. Data Retention

We retain personal information for as long as is reasonably necessary to fulfill the purposes described in this Policy, including to provide the App's features, maintain business records, comply with legal obligations, resolve disputes, and enforce our agreements. Different categories of information may be subject to different retention periods. In particular:

• Raw voice audio from speaking and pronunciation features is not retained after the session in which it was recorded. It exists only for as long as that session needs it.
• Text transcripts of your practice sessions and lesson answers are kept until you delete your account, or earlier if you delete them yourself in the App.
• Other transient processing data, such as the foreground-app signals used for the focus/app-lock feature, is not retained beyond the moment it is needed.
• Account and learning-progress data persists for as long as your account remains active.

When you request deletion of your account (see Section 10), we delete or irreversibly anonymize your personal data within a reasonable period, except where continued retention is required by law or necessary to resolve disputes or enforce our agreements.

9. Children's Privacy

The App is intended for a general audience and is not directed specifically at children under the age of 13 (or the equivalent minimum age in your jurisdiction). We do not knowingly collect personal information from a child under that age without verifiable parental consent. If we become aware that we have inadvertently collected personal information from a child under the applicable age without appropriate consent, we will take steps to delete that information promptly. If you are a parent or guardian and believe your child has provided us with personal information, please contact us using the details in Section 14.

10. Your Rights and Choices

Depending on where you live, you may have rights with respect to your personal information, which may include the right to:

• Access the personal information we hold about you
• Correct inaccurate or incomplete information, much of which you can update directly within the App
• Delete your account and associated personal information. You can start that process on our Delete account page
• Export a copy of your data in a portable format
• Object to or restrict certain processing of your information
• Withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing before withdrawal
• Opt out of non-essential analytics or session-recording features, where technically supported
• Disable the optional focus/app-lock feature and revoke its underlying system permission at any time in your device settings, immediately stopping any related processing

To delete your account, visit our Delete account page, or contact us at hello@usecomigo.com from the email address associated with your account. To exercise any of your other rights above, use the same email. We will verify your request and respond within the timeframe required by applicable law, generally within 30 days. You may also disable optional permissions such as notifications at any time from your device settings.

If you are located in the European Economic Area, the United Kingdom, or Switzerland, you have the right to lodge a complaint with your local data protection supervisory authority. If you are a California resident, you may have additional rights under California privacy law, including the right to know, delete, and correct personal information, and the right to non-discrimination for exercising your privacy rights; we do not sell or "share" personal information as those terms are defined under California law.

11. Data Security

We use administrative, technical, and organizational measures designed to protect your information against unauthorized access, alteration, disclosure, or destruction. These measures include encryption of data in transit, access controls limiting who can view or modify data, and logical separation of each account's data from other accounts. No method of electronic transmission or storage is completely secure, however, and we cannot guarantee absolute security. If we become aware of a security incident affecting your personal information, we will notify you and any applicable regulator as required by law.

12. International Data Transfers

We and our service providers may process and store information in countries other than the one in which you reside, including countries that may have data protection laws different from those of your jurisdiction. Where we transfer personal information internationally, we take steps intended to ensure an adequate level of protection for that information, consistent with applicable law, such as the use of standard contractual clauses or equivalent safeguards where required.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other operational reasons. If we make material changes, we will provide notice through the App, by posting an updated version on our website, or by other reasonable means, before the change takes effect. The "Last updated" date at the top of this Policy indicates when it was last revised. We encourage you to review this Policy periodically.

14. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our handling of your personal information, please contact us at:

Email: hello@usecomigo.com
Website: https://usecomigo.com/

We aim to respond to all privacy-related inquiries in a timely manner.