Soltura Privacy Policy

1. WHO IS RESPONSIBLE

Marcos del Vado Sanz

4500 N Federal Hwy, 33064

Email: supportsoltura@gmail.com

2. WHAT DATA WE COLLECT

Account data: your name and your email address.

Diagnosis and learning data: your answers to the level test, the text you write in production exercises, the transcripts of your conversations with the tutor, your voice recordings when you use the speaking exercises, your estimated level, the errors we detect, your study plan and your session history.

Usage data: which screens you visit, how long you study and which exercises you complete.

Device and advertising identifiers: your device advertising identifier and basic technical device data, used by our advertising provider.

Payment data: handled entirely by Apple or by Stripe. We never see or store your card numbers.

We do not collect your precise location, your contacts or your photos.

3. WHAT WE USE IT FOR

To create and maintain your account. To measure your level and detect your error patterns. To generate your lessons, your plan and your exercises. So that your progress is still there when you come back. To manage your subscription. To show advertising in the free parts of the app. To detect faults and improve the product. To answer you when you write to support.

4. PROCESSING WITH ARTIFICIAL INTELLIGENCE

This matters and we want it to be clear. The text you write, your conversation transcripts and the transcripts of your voice recordings are sent to external artificial intelligence model providers in order to analyse and correct them and to generate your lessons and exercises. Without that transfer the app cannot work: it is the mechanism of the diagnosis. We send the language content needed for the analysis, and we do not send your name or your email address alongside it.

The results returned by artificial intelligence are automatic and may contain errors. Your estimated level is an estimate for your own use, not an official certification.

5. WHO WE SHARE DATA WITH

Artificial intelligence model providers, for the analysis and content generation described above.

Google, as our advertising provider, which receives advertising identifiers and usage data in order to show ads. If you turn personalized ads off, only non-personalized ads will be shown.

Apple and Stripe, to process payments and subscriptions.

Our hosting provider, to run the app and the database.

We do not sell your data. We share the minimum necessary for each service to do its job, and only for the purposes described in this policy.

6. ADVERTISING AND TRACKING

On iOS we will ask your permission before any tracking through the advertising identifier. If you decline, you will see only non-personalized ads and the app will work exactly the same. You can change your preference at any time in Privacy Choices, inside the app, or in your device settings.

Users who state that they are under 16 are shown only non-personalized ads.

7. HOW LONG WE KEEP YOUR DATA

For as long as you keep your account open, because your profile and your plan depend on your history. If you delete your account, we erase your data from our active systems within 30 days, except what we must keep for legal or accounting obligations. Backups are overwritten within 90 days.

8. YOUR RIGHTS

You can access your data, correct it, download it, restrict its processing, object to it and delete it. You can do this from Privacy Choices and from About, inside the app, or by writing to supportsoltura@gmail.com. We will reply within 30 days at the latest.

If you are in the European Economic Area or the United Kingdom, we process your data to perform our contract with you, to comply with legal obligations and, in the case of advertising, with your consent. You can withdraw your consent at any time and lodge a complaint with your data protection authority.

If you are in California, you have the right to know what data we collect, to delete it, to correct it and to tell us not to share your personal information for cross-context behavioral advertising. The "Do not sell or share my personal information" control is in Privacy Choices. We do not discriminate against anyone who exercises their rights.

9. MINORS

Soltura is aimed at adults learning Spanish. You must be at least 13 years old to use it, and if you are under 18 you need the consent of a parent or guardian. We do not knowingly collect data from children under 13. If you believe that a child under 13 has given us data, write to us and we will delete it.

10. SECURITY

We use encrypted connections, storage with restricted access and authentication managed by our identity provider. We never store passwords in plain text. No system is infallible, so we cannot guarantee absolute security.

11. INTERNATIONAL TRANSFERS

Our providers may process data in the United States and in other countries. When we transfer data from the European Economic Area or the United Kingdom, we rely on the standard contractual clauses or another equivalent legal mechanism.

12. CHANGES TO THIS POLICY

If we change anything relevant, we will update the date above and let you know in the app or by email before the change takes effect.

13. CONTACT

supportsoltura@gmail.com