Privacy Policy

This Privacy Notice for Papagei LLC ("we," "us," or "our") describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

• Download and use our mobile application (Papagei), or any other application of ours that links to this Privacy Notice;
• Use Papagei, a mobile learning application designed to help students prepare for official German language proficiency exams at B1 and B2 levels (CEFR). The app provides diagnostic testing across the four modules (Lesen, Hören, Schreiben, Sprechen), exam-type exercises, full mock examinations, AI-powered feedback on speaking and writing, community features, progress tracking (XP, streaks, badges, leaderboards), and a structured 30-day learning program. Papagei is available on iOS and Android and offers both free features and premium subscription content. The application uses third-party AI services for speech recognition, language assessment, and automated feedback;
• Engage with us in other related ways, including any sales, marketing, or events.

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have questions, contact us at hallo@getpapagei.app.

Summary of key points

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us, the choices you make, and the features you use.

Do we process sensitive personal information? We do not process sensitive personal information.

Do we collect information from third parties? We do not collect any information from third parties.

How do we process your information? To provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We process your information only when we have a valid legal reason to do so.

When and with whom do we share personal information? We may share information in specific situations and with specific third parties.

What are your rights? Depending on where you are located, applicable privacy law may give you certain rights regarding your personal information.

How do you exercise your rights? The easiest way is by submitting a data subject access request, or by contacting us.

Table of contents

1. What information do we collect?
2. How do we process your information?
3. What legal bases do we rely on?
4. When and with whom do we share your personal information?
5. Do we use cookies and other tracking technologies?
6. Do we offer artificial intelligence-based products?
7. How do we handle your social logins?
8. How long do we keep your information?
9. Do we collect information from minors?
10. What are your privacy rights?
11. Controls for do-not-track features
12. Do United States residents have specific privacy rights?
13. Do other regions have specific privacy rights?
14. Do we make updates to this notice?
15. How can you contact us about this notice?
16. How can you review, update, or delete the data we collect from you?

1. What information do we collect?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide when you register on the Services, express an interest in obtaining information about us or our products and Services, participate in activities on the Services, or otherwise contact us. This may include: names, email addresses, usernames, passwords, contact preferences, contact or authentication data, billing addresses, debit/credit card numbers, and phone numbers.

Sensitive Information. We do not process sensitive information.

Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number and associated security code. All payment data is handled and stored by Stripe and RevenueCat. Their privacy notices are available at stripe.com/privacy and revenuecat.com/privacy.

Social Media Login Data. We may provide you the option to register using your existing social media account. If you choose this, we will collect certain profile information as described in section 7.

Application Data. If you use our application(s), we may collect — with your permission — mobile device data (device ID, model, manufacturer, operating system, version and configuration information, IP address, mobile carrier and network information, and information about the app features you access), and push notification tokens (you can opt out in your device settings). This information is primarily needed for security, operation, troubleshooting, and internal analytics.

All personal information you provide must be true, complete, and accurate, and you must notify us of any changes.

Information automatically collected

In Short: Some information — such as your IP address and/or browser and device characteristics — is collected automatically when you visit our Services.

This information does not reveal your specific identity but may include device and usage information such as IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, and information about how and when you use our Services. It is primarily needed for security, operation, and internal analytics. We also collect information through cookies and similar technologies. This includes log and usage data, device data, and location data (precise or imprecise; you can opt out via your device settings, though this may limit certain features). Our use of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.

2. How do we process your information?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.

We process your personal information to: facilitate account creation and authentication and manage user accounts; deliver and facilitate services; respond to inquiries and offer support; send administrative information; fulfill and manage your orders, payments, returns, and exchanges; enable user-to-user communications where you use features that allow it; and save or protect an individual's vital interest, such as to prevent harm.

3. What legal bases do we rely on to process your information?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason to do so under applicable law.

If you are located in the EU or UK, the GDPR and UK GDPR require us to explain the valid legal bases we rely on. These may be: consent (which you can withdraw at any time), performance of a contract, legal obligations, and vital interests. We are generally the "data controller" of the personal information described in this notice.

If you are located in Canada, we may process your information with your express or implied consent, which you can withdraw at any time. In some exceptional cases, we may be legally permitted to process your information without consent as allowed by applicable law.

4. When and with whom do we share your personal information?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We may share your personal information in connection with business transfers (any merger, sale of company assets, financing, or acquisition), with other users when you share information or interact with public areas of the Services, and via an offer wall where a unique identifier such as your user ID may be shared with the offer wall provider to prevent fraud and credit your account with a reward.

5. Do we use cookies and other tracking technologies?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services, to maintain security, prevent crashes, fix bugs, save preferences, and assist with basic functions. We also permit third parties and service providers to use tracking technologies for analytics and advertising. Specific information is set out in our Cookie Notice at getpapagei.app/cookies. We may share information with Google Analytics to track and analyze use of the Services; you can opt out via Google's opt-out tools.

6. Do we offer artificial intelligence-based products?

In Short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.

We provide AI Products through third-party AI Service Providers, including Microsoft Azure AI and OpenAI. Your input, output, and personal information will be shared with and processed by these providers to enable your use of our AI Products. Our AI Products are designed for text analysis and natural language processing. All personal information processed using our AI Products is handled in line with this Privacy Notice and our agreements with third parties.

7. How do we handle your social logins?

In Short: If you choose to register or log in using a social media account, we may have access to certain information about you.

Where you register or log in using third-party social media account details, we will receive certain profile information (often your name, email address, friends list, and profile picture). We use this information only for the purposes described in this Privacy Notice. We do not control, and are not responsible for, other uses of your personal information by your social media provider.

8. How long do we keep your information?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

No purpose in this notice will require us keeping your personal information for longer than six (6) months past the termination of the user's account. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or securely store and isolate it from further processing until deletion is possible.

9. Do we collect information from minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction.

By using the Services, you represent that you are at least 18 (or the equivalent age in your jurisdiction), or that you are the parent or guardian of such a minor and consent to their use of the Services. If we learn that personal information from users under 18 has been collected, we will deactivate the account and take reasonable measures to promptly delete such data. If you become aware of any data we may have collected from children under 18, please contact us at hallo@getpapagei.app.

10. What are your privacy rights?

In Short: Depending on your location, you may have rights that allow greater access to and control over your personal information.

In some regions (like the EEA, UK, Switzerland, and Canada), you have rights that may include: to request access and obtain a copy of your personal information; to request rectification or erasure; to restrict processing; to data portability; and not to be subject to automated decision-making. You can make a request using the contact details in section 15. If you are in the EEA or UK and believe we are unlawfully processing your personal information, you have the right to complain to your data protection authority. If you are in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: You can withdraw your consent at any time by contacting us or updating your preferences. This will not affect the lawfulness of processing before withdrawal.

Opting out of marketing: You can unsubscribe at any time by clicking the unsubscribe link in our emails or contacting us. We may still send you service-related messages.

Account information: You can review or change your account information, or terminate your account, in your account settings or by contacting us. Upon termination, we will deactivate or delete your account and information from our active databases, though we may retain some information to prevent fraud, troubleshoot, assist investigations, enforce our legal terms, and/or comply with applicable legal requirements.

11. Controls for do-not-track features

Most browsers and some mobile operating systems include a Do-Not-Track ("DNT") feature. As no uniform technology standard for recognizing and implementing DNT signals has been finalized, we do not currently respond to DNT browser signals. If a standard is adopted that we must follow, we will inform you in a revised version of this Privacy Notice.

12. Do United States residents have specific privacy rights?

In Short: If you are a resident of certain US states, you may have the right to request access to and details about the personal information we maintain about you, correct inaccuracies, get a copy of, or delete your personal information.

These rights include the right to know whether we are processing your personal data, to access it, to correct inaccuracies, to request deletion, to obtain a copy, to non-discrimination for exercising your rights, and to opt out of processing for targeted advertising, sale, or profiling. Depending on your state, additional rights may apply. We have not sold or shared personal information to third parties for a business or commercial purpose in the preceding twelve (12) months, and we will not do so in the future.

To exercise these rights, contact us by submitting a data subject access request, emailing hallo@getpapagei.app, or visiting our contact page. Upon receiving your request, we will verify your identity. If we decline to take action, you may appeal by emailing hallo@getpapagei.app.

13. Do other regions have specific privacy rights?

In Short: You may have additional rights based on the country you reside in.

Australia and New Zealand: We collect and process your personal information under Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020. You have the right to request access to or correction of your personal information. If you believe we are unlawfully processing your personal information, you may complain to the Office of the Australian Information Commissioner or the Office of the New Zealand Privacy Commissioner.

Republic of South Africa: You have the right to request access to or correction of your personal information. You may contact the Information Regulator (South Africa) if unsatisfied with how we address a complaint.

14. Do we make updates to this notice?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

The updated version will be indicated by an updated date at the top of this Privacy Notice. If we make material changes, we may notify you by prominently posting a notice or by directly sending you a notification.

15. How can you contact us about this notice?

If you have questions or comments about this notice, you may email us at hallo@getpapagei.app or contact us by post at:

Papagei LLC
13 Rue du Général de Gaulle
La Madeleine 59110
France

If you are a resident in the European Economic Area, we are the "data controller" of your personal information. We have appointed ZOA EKIDI Fidèle Galilée as our representative in the EEA. You can contact them by email at galileezoa@gmail.com, by phone at +33 6 52 97 35 73, or by post to:

13 Rue de Tournai
La Madeleine 59110
France

16. How can you review, update, or delete the data we collect from you?

You have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please contact us.