Privacy Policy

1 Overview

This Privacy Policy describes how Scholarly Apps ("we," "our," or "us") collects, uses, shares, and safeguards personal information when you use our mobile application PathLingo (the "App") and related services (collectively, the "Services").

By downloading, accessing, or using PathLingo, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with the terms of this policy, please do not use our Services.

This policy applies to all users of PathLingo globally, including users who access the app through the Google Play Store, Apple App Store, or any other distribution platform.

2 Information We Collect

2.1 Information You Provide Directly

When you create an account or interact with PathLingo, you may voluntarily provide us with certain personal information, including:

• Account Information: Name, email address, username, password, and profile picture when you register for an account.
• Profile Information: Preferred language(s), native language, learning goals, and proficiency level.
• Learning Data: Lesson progress, quiz responses, vocabulary lists, streak data, XP scores, and other learning activity within the app.
• Audio Data: Voice recordings when you use the pronunciation practice feature. These recordings are processed to provide feedback and are not stored on our servers unless you explicitly opt in.
• Communications: Messages, feedback, support requests, or survey responses you send to us.
• Payment Information: If you make any voluntary donations or purchase optional premium features (if applicable in the future), payment data is processed by third-party payment processors and is never stored on our servers.

2.2 Information Collected Automatically

When you use PathLingo, we automatically collect certain technical and usage information:

2.3 Information from Third-Party Sources

If you choose to sign in using a third-party service (such as Google Sign-In or Apple Sign-In), we may receive your name, email address, and profile picture from that service, in accordance with the permissions you grant and that service's privacy policy.

3 How We Use Your Information

We use the information we collect for the following purposes:

• Provide & Maintain the Service: To deliver personalized lessons, track your progress, maintain streaks, and ensure the app functions correctly across your devices.
• Personalize Your Experience: To adapt lesson difficulty, recommend content based on your learning patterns, and tailor the app interface to your preferred language.
• Improve Our Services: To analyze usage trends, conduct research, identify bugs, and develop new features that enhance the learning experience.
• Communicate With You: To send streak reminders, learning tips, product updates, and respond to your support requests. You can opt out of non-essential communications at any time.
• Ensure Security: To detect, prevent, and respond to fraud, abuse, security risks, and technical issues.
• Legal Compliance: To comply with applicable laws, regulations, legal processes, or enforceable governmental requests.
• Aggregate Analytics: To create anonymized, aggregated statistics about app usage that cannot identify any individual user. These statistics help us improve our product and may be shared publicly.

4 Data Sharing & Disclosure

We may share your information only in the following limited circumstances:

4.1 Service Providers

We engage trusted third-party companies and individuals to perform services on our behalf ("Service Providers"), such as cloud hosting, analytics, crash reporting, email delivery, and customer support. These providers have access to your personal information only to perform specific tasks on our behalf and are contractually obligated not to disclose or use it for any other purpose.

4.2 Legal Requirements

We may disclose your personal information if required to do so by law or in response to valid legal requests by public authorities, including to meet national security or law enforcement requirements, court orders, or legal processes served on us.

4.3 Safety & Rights Protection

We may share information when we believe in good faith that disclosure is necessary to protect your safety or the safety of others, investigate fraud, or respond to a government request.

4.4 Business Transfers

If Scholarly Apps is involved in a merger, acquisition, reorganization, or sale of assets, your personal information may be transferred as part of that transaction. We will notify you via email and/or prominent notice within the app of any change in ownership or uses of your personal information.

4.5 With Your Consent

We may share your information for any other purpose with your explicit consent.

5 Data Retention

We retain your personal information only for as long as necessary to provide you with our Services, or as required by law. Specifically:

• Account Data: Retained for as long as your account is active. Upon account deletion, personal data is purged within 30 days, except where we are legally required to retain it.
• Learning Progress: Retained while your account is active to ensure your progress is preserved across sessions and devices.
• Audio Recordings: Pronunciation recordings are processed in real-time and are not persistently stored on our servers unless you explicitly opt in to contribute to improving our speech recognition models.
• Usage & Analytics Data: Retained in identifiable form for up to 24 months, after which it is anonymized or deleted.
• Support Tickets: Retained for up to 36 months after resolution for quality assurance and legal purposes.

6 Data Security

We take the security of your data seriously and implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. Our security measures include:

• Encryption in Transit: All data transmitted between the app and our servers is encrypted using TLS 1.3 (Transport Layer Security).
• Encryption at Rest: Personal data stored on our servers is encrypted using AES-256 encryption.
• Access Controls: Strict role-based access controls limit employee access to personal data to only those who need it to perform their job functions.
• Regular Audits: We conduct regular security assessments and vulnerability testing of our systems.
• Secure Infrastructure: We use reputable cloud service providers that maintain SOC 2 Type II compliance and robust physical security measures.
• Incident Response: We maintain a documented incident response plan. In the event of a data breach affecting your personal information, we will notify you and applicable authorities as required by law.

While we strive to use commercially acceptable means to protect your personal information, no method of transmission over the Internet or method of electronic storage is 100% secure. We cannot guarantee absolute security.

7 Your Rights & Choices

Depending on your location, you may have the following rights regarding your personal information:

• Access: Request a copy of the personal data we hold about you.
• Correction: Request that we correct any inaccurate or incomplete personal data.
• Deletion: Request that we delete your personal data ("right to be forgotten").
• Data Portability: Request a copy of your data in a structured, commonly used, machine-readable format (JSON or CSV).
• Restriction: Request that we restrict the processing of your personal data under certain circumstances.
• Objection: Object to our processing of your personal data for direct marketing or based on legitimate interests.
• Withdraw Consent: Withdraw your consent to data processing at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
• Opt-Out of Communications: Unsubscribe from marketing emails by clicking the "unsubscribe" link in any email, or by adjusting your notification preferences within the app.

8 Children's Privacy

PathLingo is designed to be used by individuals of all ages, including children. We are committed to protecting the privacy of children and comply with applicable children's privacy laws, including the Children's Online Privacy Protection Act (COPPA) in the United States and similar regulations globally.

• Age Screening: During registration, we ask users to confirm their age. Users under 13 years of age (or the applicable age of consent in their jurisdiction) are required to have parental or guardian consent before creating an account.
• Limited Data Collection: For child users, we limit the data we collect to only what is strictly necessary to provide the educational service (learning progress, basic account data). We do not collect more data than is reasonably necessary.
• No Behavioral Advertising: We do not serve behavioral or targeted advertising to child users.
• Parental Controls: Parents or guardians can review, modify, or request deletion of their child's personal data by contacting us at info@scholarlyapps.com.
• No Unmonitored Communication: Child users are not given access to features that allow unmonitored communication with other users.

If we learn that we have collected personal information from a child under the age of 13 without verifiable parental consent, we will take steps to delete that information as quickly as possible. If you believe we might have any information from or about a child under 13, please contact us immediately.

9 International Data Transfers

Scholarly Apps operates globally, and your personal information may be transferred to and processed in countries other than the country in which you reside. These countries may have data protection laws that are different from the laws of your country.

When we transfer personal data internationally, we ensure appropriate safeguards are in place, including:

• Standard Contractual Clauses (SCCs) approved by the European Commission for transfers from the EU/EEA.
• Data Processing Agreements (DPAs) with all third-party service providers.
• Adequacy decisions where applicable (e.g., transfers to countries deemed adequate by the European Commission).

10 Third-Party Services

PathLingo may integrate or use the following categories of third-party services. Each service operates under its own privacy policy:

We carefully vet all third-party service providers and require them to comply with applicable data protection laws. We encourage you to review the privacy policies of any third-party services you interact with through our app.

11 Cookies & Tracking Technologies

Our mobile app does not use browser cookies. However, our website (scholarlyapps.com) and the app may use the following tracking technologies:

• Local Storage & App Preferences: We store your preferences, authentication tokens, and cached learning data locally on your device to ensure a seamless experience.
• Analytics SDKs: We use mobile analytics tools that may employ device identifiers to collect anonymized usage statistics.
• Advertising Identifier: We do not collect or use your device's Advertising ID (Google AAID / Apple IDFA) for advertising purposes. If collected by analytics SDKs, it is used solely for aggregated analytics.

You can reset your device's advertising identifier or opt out of personalized advertising through your device's privacy settings.

12 California Residents (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA):

• Right to Know: You may request that we disclose what personal information we have collected about you in the past 12 months, including the categories and specific pieces of data, the sources, the business purposes, and the categories of third parties with whom we shared it.
• Right to Delete: You may request that we delete personal information we have collected from you, subject to certain exceptions.
• Right to Correct: You may request that we correct inaccurate personal information.
• Right to Opt-Out of Sale/Sharing: We do not sell or share your personal information as defined by the CCPA/CPRA. Therefore, no opt-out is necessary.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA/CPRA rights.
• Right to Limit Use of Sensitive Personal Information: We do not use sensitive personal information beyond what is necessary to provide our Services.

To submit a CCPA/CPRA request, please email info@scholarlyapps.com with the subject line "CCPA Request." We may need to verify your identity before processing your request.

13 EU/EEA Residents (GDPR)

If you are in the European Union or European Economic Area, the General Data Protection Regulation (GDPR) provides you with enhanced rights over your personal data:

• All rights listed in Section 7 ("Your Rights & Choices") are fully applicable to you under GDPR.
• You have the right to lodge a complaint with your local Data Protection Authority (DPA) if you believe our processing of your personal data violates applicable law.
• Our legal bases for processing are described in Section 3.
• For international transfers, see Section 9.

14 Changes to This Policy

We may update this Privacy Policy from time to time. When we make changes, we will:

1. Update the "Effective Date" at the top of this page.
2. Notify you of material changes via an in-app notification and/or email at least 30 days before the changes take effect.
3. Provide a summary of what changed for easy review.
4. Where required by law, obtain your consent before applying changes that affect how your personal data is processed.

We encourage you to review this page periodically to stay informed about how we protect your information. Your continued use of PathLingo after the effective date of any updated Privacy Policy constitutes your acceptance of the changes.

15 Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please don't hesitate to reach out: