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Privacy Policy

Last updated: January 12, 2025

At Ninshoma, we take your privacy seriously. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application and services.

1. Information We Collect

1.1 Information You Provide

  • Account Information: When you create an account, we collect your email address, name, and password.
  • Profile Information: Target language, current proficiency level, learning goals, and preferences.
  • User Content: Messages, audio recordings for pronunciation practice, lesson responses, and vocabulary lists.
  • Payment Information: Processed securely by our payment processor (RevenueCat/Apple/Google). We do not store your full payment card details.

1.2 Information Collected Automatically

  • Usage Data: Lessons completed, time spent learning, conversation history, and progress metrics.
  • Device Information: Device type, operating system, unique device identifiers, and mobile network information.
  • Location Data: General location (country/region) for language recommendations and content localization.
  • Analytics Data: App performance, crash reports, and feature usage statistics.

1.3 Information from Third Parties

  • Authentication Services: If you sign in using Apple, Google, or other OAuth providers.
  • Payment Providers: Subscription status and transaction information from app stores.

2. How We Use Your Information

We use your information to:

  • Provide and maintain our language learning services
  • Personalize your learning experience with AI-powered recommendations
  • Process your subscription and transactions
  • Send you important updates, security alerts, and customer support messages
  • Improve our AI models and teaching methodology
  • Analyze usage patterns to enhance app features and performance
  • Detect and prevent fraud, abuse, and security incidents
  • Comply with legal obligations and enforce our Terms of Service

3. How We Share Your Information

We do not sell your personal information. We may share your information with:

3.1 Service Providers

  • Cloud Infrastructure: Supabase for secure data storage
  • AI Services: Google Gemini AI and OpenAI for conversation and learning features
  • Payment Processing: RevenueCat, Apple, and Google for subscription management
  • Analytics: Privacy-focused analytics to improve our services

3.2 Legal Requirements

We may disclose your information if required by law, court order, or government request, or to protect our rights, property, or safety.

3.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the new owner.

4. Data Security

We implement industry-standard security measures to protect your information:

  • Encryption of data in transit (TLS/SSL) and at rest
  • Secure authentication with bcrypt password hashing
  • Regular security audits and vulnerability assessments
  • Access controls and monitoring of our systems
  • Employee training on data protection and security best practices

However, no method of transmission over the internet is 100% secure. We cannot guarantee absolute security.

5. Your Privacy Rights

5.1 Access and Correction

You can access and update your account information through the app settings.

5.2 Data Deletion

You can request deletion of your account and personal data by contacting us at privacy@ninshoma.com. We will delete your data within 30 days, except where required by law to retain it.

5.3 Export Your Data

You can request a copy of your personal data in a portable format.

5.4 Opt-Out

  • Marketing Communications: Unsubscribe from promotional emails using the link in the email.
  • Analytics: Disable analytics tracking in app settings.

5.5 Regional Rights

Depending on your location, you may have additional rights under GDPR, CCPA, or other privacy laws:

  • Right to access your data
  • Right to rectification of inaccurate data
  • Right to erasure ("right to be forgotten")
  • Right to restrict processing
  • Right to data portability
  • Right to object to processing
  • Right to withdraw consent

6. Children's Privacy

Ninshoma is not intended for children under 13 years of age (or 16 in the EU). We do not knowingly collect personal information from children. If you are a parent or guardian and believe your child has provided us with personal information, please contact us at privacy@ninshoma.com.

7. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. We ensure appropriate safeguards are in place for such transfers, including:

  • Standard Contractual Clauses approved by the European Commission
  • Data Processing Agreements with our service providers
  • Compliance with applicable data protection laws

8. Data Retention

We retain your information for as long as necessary to provide our services and fulfill the purposes outlined in this policy. Specifically:

  • Account Data: Until you request deletion or close your account
  • Learning History: Retained to track your progress and personalize learning
  • Usage Analytics: Aggregated and anonymized after 24 months
  • Billing Records: Retained for 7 years for tax and accounting purposes

9. Cookies and Tracking

Our mobile app does not use cookies. However, we use similar technologies:

  • Local Storage: To save your preferences and session data
  • Analytics SDKs: To understand app usage and improve performance
  • Advertising Identifiers: We do not use advertising IDs for targeted advertising

10. Third-Party Links

Our app may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to read their privacy policies.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by:

  • Posting the new policy in the app
  • Updating the "Last updated" date
  • Sending you an email notification (for significant changes)

Your continued use of Ninshoma after changes become effective constitutes your acceptance of the updated policy.

12. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Email: privacy@ninshoma.com

Support: Visit our Support Center

Data Protection Officer: dpo@ninshoma.com

13. Compliance

Ninshoma complies with:

  • GDPR: General Data Protection Regulation (EU)
  • CCPA: California Consumer Privacy Act (USA)
  • COPPA: Children's Online Privacy Protection Act (USA)
  • PIPEDA: Personal Information Protection and Electronic Documents Act (Canada)
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