Privacy Policy
This Privacy Policy explains how the mobile application T.R.A.I.N — Talk, Read and Interact Now (the “App”) collects, uses, stores, and shares personal data.
Email: support@trainupstudio.com
1. Scope
This Policy applies when you install or use the App, create an account, study words, upload media, create or open a shared collection link, receive notifications, view advertising, make purchases, or contact us. It does not govern third-party services that have their own privacy policies.
2. Information we process
- Account and profile data: account identifier, email address, display/profile information, authentication provider, preferred language, and settings.
- Learning data: words and categories, learning and review history, answers, progress, experience, achievements, streaks, completed exercises, selected learning modes, and virtual resources used in the App.
- User content and media: text, images, photos, video, audio, or other files that you choose to create, select, or upload. Uploaded media may be stored in cloud storage, including Cloudflare R2, so that App features can work across sessions and devices.
- Shared collection data: when you choose to share a category, we create a versioned snapshot containing its title and description, your display name, the learning and translation languages, words and translations, and any images, audio, or notes that you elect to include. We also process the sharing token and events such as link creation, preview opening, saving, removal, and learning activity. Your email address and sign-in credentials are not displayed in the shared collection.
- Device and notification data: device type, operating system, app version, language, push notification token, and notification preferences.
- Purchase and subscription data: product identifier, subscription status, transaction identifier, purchase time, entitlement, and store environment. We do not receive or store your complete bank-card details.
- Advertising and consent data: advertising identifiers where permitted, consent choices, limited device information, ad impressions, clicks, and related diagnostics. Personalized advertising is used only where permitted and after any consent required by law.
- Diagnostics and security data: crash and performance information, request logs, IP address, timestamps, and events needed to troubleshoot problems, protect accounts, and prevent abuse.
- Support communications: messages and information you send when contacting support.
- AI-assisted feature data: text or other content submitted to an AI-assisted feature, together with the minimum context required to generate the requested result. Do not submit confidential or sensitive personal information unless it is necessary.
3. Device permissions
Depending on the features you use, the App may request access to the camera, photos, files/media, microphone, or notifications. Access is used only for the feature you select. You can withdraw a permission in your device settings, although the related feature may then stop working.
4. Why we use data and our legal bases
| Purpose | Legal basis |
|---|---|
| Create and manage your account; provide learning, media, synchronization, and support features. | Performance of our contract with you. |
| Create shared collection links, display their previews, let recipients save read-only collections, preserve separate learning progress, and provide updated collection versions. | Performance of our contract with you and your action in choosing to share or save a collection. |
| Process purchases, subscriptions, entitlements, and restore transactions. | Performance of our contract and compliance with legal obligations. |
| Send service messages and requested push notifications. | Performance of our contract and, where required, your consent. |
| Show and measure advertising. | Your consent where required; otherwise our legitimate interests, subject to applicable law and your choices. |
| Improve stability, understand feature performance, secure the App, and prevent fraud or abuse. | Our legitimate interests in operating and protecting the App. |
| Comply with tax, accounting, consumer-protection, and lawful authority requirements. | Compliance with legal obligations. |
5. Service providers and sharing
We do not sell your personal data. We disclose only the information reasonably necessary to providers that help us operate the App, including:
- Apple App Store and Google Play for distribution, billing, and transaction validation;
- RevenueCat for subscription and entitlement management;
- Google AdMob and Google consent services for advertising, ad measurement, and privacy choices;
- Cloudflare, including R2 for infrastructure, delivery, and storage of uploaded media;
- Apple and Google push notification services for delivering notifications;
- OpenAI or another disclosed AI provider when you use an AI-assisted feature;
- hosting, database, monitoring, security, and technical support providers used to run the App.
We may also disclose information when required by law, to protect users or the App, or as part of a business transfer subject to appropriate safeguards. Providers act under their own terms and privacy notices or under contractual processing obligations, as applicable.
6. Shared collections and link access
A shared collection link is unlisted, but it is not restricted to a named recipient. Anyone who receives the link may open a preview and may forward the link to another person. The preview may show your display name, the collection title and description, its language pair, words and translations, and any media or notes you selected for inclusion. Do not include confidential, sensitive, or third-party personal information in a collection that you share.
A signed-in recipient with a compatible native and learning language may save a read-only version of the collection. The recipient’s learning progress is stored separately from yours. If you later share a new version, a recipient may choose whether to switch to that version. Shared media is copied to storage used for the shared collection so that saved copies remain usable; consequently, content lawfully shared with and saved by another user may remain available to that user even if you later remove the original category, word, note, or media from your own dictionary.
7. Advertising choices
Where required, the App presents a consent flow before requesting or using data for personalized advertising. You can review or change available advertising privacy choices from the App’s settings when that option is available, or through your device settings. If consent is refused or unavailable, the App may show non-personalized or limited ads, or no ad, depending on provider availability and applicable law.
8. Storage and retention
We retain account and learning data while your account remains active and for a limited period afterward where necessary to complete deletion, resolve disputes, secure the service, or meet legal requirements. Uploaded cloud media that has not been shared is deleted when the related content or account is deleted, subject to a short period for backups, technical queues, or recovery systems. Versioned shared collections, link records, selected shared media, and associated activity records may be retained while needed to keep lawfully saved recipient copies available, operate the sharing feature, prevent abuse, or meet legal requirements. Purchase, consent, tax, fraud-prevention, and security records may be retained longer where required by law or necessary to establish or defend legal claims.
9. Account and data deletion
You can use the deletion option available in the App, where provided, or email support@trainupstudio.com. Deleting an account removes or anonymizes associated personal data from active systems, including associated cloud media, unless the content was lawfully shared with and saved by another user or retention is required by law or necessary for security, fraud prevention, dispute resolution, or legal claims. Where a saved shared copy must remain functional, we may retain the shared content while removing or anonymizing account identifiers that are no longer necessary. Removing the App from your device does not by itself delete your server-side account.
App-store purchase records and subscription cancellation are controlled by Apple or Google. You may need to cancel a subscription separately in your store account.
10. Your privacy rights
Subject to applicable law, you may request access, correction, deletion, restriction, portability, or objection to processing, and may withdraw consent at any time without affecting earlier lawful processing. To make a request, contact support@trainupstudio.com. We may ask for reasonable information to verify your identity.
If you are in Spain or the EEA, you may lodge a complaint with the Spanish Data Protection Agency (AEPD) or your local supervisory authority.
11. International data transfers
Some providers may process data outside Spain or the European Economic Area. Where required, we rely on an adequacy decision, approved standard contractual clauses, or another lawful transfer mechanism, together with appropriate safeguards.
12. Security
We use reasonable technical and organizational safeguards, including encrypted network connections, access controls, and measures intended to limit unauthorized access. No service can guarantee absolute security, and you are responsible for keeping your device and account credentials secure.
13. Children
The App is not directed to children under 13. We do not knowingly collect personal data from a child who cannot legally consent to the processing without the required permission of a parent or guardian. If you believe a child has provided personal data improperly, contact us so that we can investigate and delete it where appropriate.
14. Changes to this Policy
We may update this Policy to reflect changes in the App, providers, or law. The current version will be posted at this location with a revised effective date. Where required, we will provide additional notice or request consent.
15. Contact
Questions and privacy requests may be sent to support@trainupstudio.com.