ParlumiPrivacy Policy
Last updated: 09/27/2026
In short: we store what’s needed for the app to work and for your progress not to get lost: your learning activity and, if you create an account, what Apple shares with us when you sign in. There are no ads, we don’t track you across apps, and we don’t sell or share your data. You can delete everything from the app, in Profile → Settings → Delete account and data, or from this page.
1. Who is the controller
The controller of your data is Artsessions, S.L.U., with Spanish tax ID (NIF) B64848997 and registered address at C/ Llull 240, 08005 Barcelona, Spain. For any privacy question, you can write to hello@replai.net.
2. What data we process
Even if you don’t have an account, to save and sync your progress:
- Random identifiers for your device and your user, created by the app. They are not Apple’s advertising identifier and can’t be used to find out who you are.
- Technical data about your iPhone: model, iOS version, language and region settings, preferred languages, time zone and app version.
- Your preferences: your language, the languages you’re learning and when you started each one, your daily goal, your reminder time and, if you tell us, your name and how you’d like us to address you (man, woman or prefer not to say), which we use only to teach you words in the form that applies to you.
- Your learning activity: lessons completed, the result of each exercise, the answers you type and, in speaking exercises, the text your iPhone recognized from what you said, XP, streak, gems, lives and the pending review for each word.
- Problems you report to us from an exercise.
If you create an account with Sign in with Apple: the identifier Apple assigns to Parlumi and your name, if you choose to share it. Apple also tells us your email address (or its private relay address, if you choose to hide it): we don’t store it, only an encrypted, irreversible fingerprint (hash) that’s used to confirm your identity if you ask to delete your account from the website. We never receive your Apple password.
IP address: like any internet service, we receive it when you connect. When you tap “Start” for the first time, we use it to estimate your country and include it, along with your iPhone’s technical data, in an internal email notification to the Parlumi team. We don’t store it in our database. If you ask to delete your account from the website, the email address you enter also reaches the team in a notification, so we can help you if we can’t find the account.
Microphone (speaking exercises): only if you give permission, and only while you’re touching the microphone in a pronunciation exercise. What you say is converted into text by Apple’s speech recognition, on the iPhone itself whenever the language allows it (otherwise, Apple processes it under its Privacy Policy). Parlumi doesn’t store or send the audio: only the recognized text, as your answer to the exercise. You can turn off these exercises in the app’s Settings or remove the permission in your iPhone’s Settings.
This website uses technical cookies, which don’t need your consent: hl, to remember the language you choose, and a security cookie on forms. If you accept it in the cookie notice, it also uses Google Analytics (Google Ireland Limited) to see which pages are visited: it stores the _ga cookies for up to 2 years, and Google may process data in the United States under the EU-US Data Privacy Framework. We don’t load it until you accept, it runs without Google Signals or ad personalisation, and you can withdraw your consent at any time in “Cookie settings” at the bottom of the page.
What we don’t process: your location, contacts, photos or camera, or recordings of your voice. The voice in the exercises is generated by the iPhone itself. We don’t use third-party advertising or analytics tools.
3. What we use it for and on what legal basis
| Purpose | Legal basis (GDPR) |
|---|---|
| Providing the service: your courses, your progress, syncing across devices and your account. | Performance of the contract for using the app (Art. 6(1)(b)). |
| Improving the courses with accuracy statistics and by reviewing written answers so we can accept the ones that are correct. | Legitimate interest in improving the content (Art. 6(1)(f)). You can object. |
| Knowing when someone starts using the app (the internal notification when you tap “Start”) and giving you support. | Legitimate interest in understanding how the service is used (Art. 6(1)(f)). |
| Enforcing each plan’s limits, preventing abuse and maintaining security. | Legitimate interest (Art. 6(1)(f)). |
We don’t make automated decisions that have legal effects on you, and we don’t build profiles for commercial purposes.
4. How long we keep it
- Your account and your progress, for as long as you use the app. If you delete it (from the app or from the website), at that moment we erase everything that identifies you: the link to your Apple ID, the fingerprint of your email address, your name, the link to your device, your sessions and anything you’ve typed. We keep only anonymous statistical data (sign-up date, languages and progress), with no link to you, so that we know, for example, how many people have signed up.
- The text of your written answers and of what was recognized in speaking exercises, 90 days. After that, we only keep whether they were correct or not.
- The detailed activity log, 12 months. Your progress (lessons completed, XP, streak) is kept.
- If you use the app without an account and 12 months go by without any activity, we anonymize your data in the same way.
- If you sign out without having an account, what you’ve done on the iPhone is deleted and anonymized on our servers (the app asks you to confirm first).
5. Who we share it with
We don’t sell or share your data. Only the providers that deliver a service to us have access to it, under a data processing agreement:
- Server hosting: [pending: hosting provider].
- Email delivery (internal and admin panel notifications; we don’t send emails to you): [pending: email provider].
Our servers are located in the European Union. If any provider processed data outside the European Economic Area, it would do so with the safeguards required by the GDPR, such as the European Commission’s standard contractual clauses.
If you sign in with Apple or make purchases on the App Store, Apple processes your data as an independent controller under its own Privacy Policy.
We would only disclose data to authorities when required by law.
6. Minimum age
Parlumi is for people 14 years of age or older, the age from which Spanish law allows people to consent to the processing of their own data. By using the app, you confirm that you meet this age. If you’re a parent or guardian and believe that a child under 14 has given us data, write to us and we’ll delete it.
7. Your rights
You can ask us to access your data, correct it, delete it, object to its processing, restrict it or receive it in a portable format. To delete everything, you don’t need to write to us: in the app, go to Profile → Settings → Delete account and data, or without the app, use Delete your account. For anything else, write to hello@replai.net from the email address associated with your Apple account. If you don’t have an account, tell us your iPhone model and the day you started so we can locate your data. We’ll reply within one month at most.
If you believe we haven’t handled your request properly, you can file a complaint with the Spanish Data Protection Agency (AEPD) or with the data protection authority in your country.
8. Security
All communications are encrypted (HTTPS). Access to the API uses short-lived tokens, Apple credentials are stored encrypted, and access to the internal admin panel is restricted to authorized people.
9. Changes to this policy
If we change anything important, we’ll let you know in the app. The date at the top shows the latest version. Your use of the app is also governed by the Terms of Use.