This policy describes the TuringLingo website and Android application as they operate today. We will update it before introducing a new use of personal data, such as analytics, advertising, marketing messages, or external AI processing.
1. Who is responsible for your data?
Conscious Green ICT B.V., trading under the TuringLingo brand, is the controller for personal data processed through TuringLingo. Its address is Orionstraat 38, 1033 EV Amsterdam, the Netherlands. Conscious Green ICT B.V. is registered with the Dutch Chamber of Commerce under KvK number 92141471 and has VAT identification number NL865902495B01.
Privacy questions and requests can be sent to privacy@turinglingo.com or to the postal address above.
2. Scope
This policy applies to the TuringLingo website, the TuringLingo Android application, account authentication, courses, Interview Prep, and messages sent through the website or by email. Third-party services have their own privacy notices when they process data for their own purposes.
3. Data we process, why, and our legal basis
| Data | Purpose | Legal basis |
|---|---|---|
| Account and authentication data, including email address, display name, profile image when supplied by Google, Firebase user identifier, sign-in status, and authentication security signals | Create and secure your account, sign you in, and provide account support | Performance of a contract or steps requested before entering one; legitimate interests in account and service security |
| Learning progress, installed courses, points, streaks, goals, settings, and preferences stored locally on your device | Provide the learning experience and remember your progress and choices | Performance of a contract |
| Technical and security data, such as IP address, date and time, requested URL, device or browser information, and error or security records generated when the website, Firebase authentication, Firebase Hosting, or the course catalogue is accessed | Deliver the service, protect it from abuse, troubleshoot faults, and maintain reliability | Legitimate interests in operating a secure and reliable service |
| Name, email address, subject, message, and time of submission when you contact us | Deliver and answer your message and keep an appropriate support record | Steps at your request, performance of a contract, or legitimate interests in customer support |
TuringLingo currently does not use advertising, behavioural tracking, marketing mailing lists, website analytics, or external AI services. Google sign-in is optional; email-link sign-in and guest mode remain available.
4. Data stored on your device
Course progress, points, streaks, goals, installed-course information, language and theme preferences, and similar learning state are stored locally using the application database and operating-system storage. Authentication refresh tokens are stored using the device's secure storage. If you sign in, this learning data is also synchronised to your account so that it is yours rather than the device's: completed lessons, points, bytes, streak, daily goal, and the list of courses you installed are stored in Cloud Firestore under your account identifier, and come back when you sign in on another device. If you use TuringLingo as a guest, nothing leaves the device.
You can remove local data by clearing the application's storage or uninstalling it. A backup that you export is controlled by you and remains wherever you choose to save it.
5. Who receives data?
| Provider | Service and data involved | Role |
|---|---|---|
| Namecheap, Inc. and its hosting affiliates | Website hosting, server and security logs, website contact-form delivery, and TuringLingo email hosting | Processor acting under its terms and data-processing addendum |
| Google Firebase | Firebase Authentication for email-link and Google sign-in; Firebase Hosting for authentication links; Cloud Firestore for delivery of the public course catalogue and, for signed-in users, for storage of learning progress under the account identifier | Processor for the Firebase services used by TuringLingo |
| Google Play and Google sign-in | App distribution and, when you choose it, authentication with your Google account | Google may also act as an independent controller for data it collects directly under its own privacy notice |
We do not sell personal data. We may disclose information where required by law or where reasonably necessary to establish, exercise, or defend legal claims. Provider information is available in the Firebase privacy information and the Namecheap Data Processing Addendum.
6. International transfers
Firebase Authentication is operated from the United States, and Google and Namecheap may process data in countries outside the European Economic Area. Where an adequacy decision does not apply, transfers are covered by contractual safeguards such as the European Commission's Standard Contractual Clauses and the providers' applicable data-processing terms. You may contact us to request information about the safeguards relevant to your data.
7. Retention
- Firebase account data: retained while your account is active. We action a verified deletion request without undue delay and normally within one month. Google states that deleted authentication information may take up to 180 days to be removed from live and backup systems.
- Local learning data: retained on your device until you clear the app's storage, uninstall it, or overwrite it by restoring another backup.
- Contact and support messages: normally retained for up to 12 months after the matter is resolved, then deleted through routine mailbox housekeeping unless a legal reason requires longer retention.
- Website and security logs: kept only through the hosting provider's automatic rotation and not intentionally archived by TuringLingo beyond 90 days, unless a specific security incident or legal obligation requires longer retention.
- Legally required records: retained only for the period required by applicable law.
8. Recommendations and automated processing
TuringLingo may use learning activity stored on your device together with course metadata to suggest what to study next. These suggestions are produced within the application, can be ignored or changed, and do not produce legal or similarly significant effects. They do not determine employment, admission, credit, insurance, or certification outcomes.
9. Your rights
Subject to the GDPR and applicable law, you may request access, correction, deletion, restriction, data portability, or object to processing based on legitimate interests. Where processing is based on consent, you may withdraw it at any time without affecting earlier lawful processing.
Send a request to privacy@turinglingo.com. We may request proportionate information to verify your identity. We normally respond within one month, subject to extensions permitted by law. You may also complain to the Dutch Data Protection Authority or the competent supervisory authority where you live or work.
10. Security
TuringLingo uses HTTPS for network communications, operating-system secure storage for authentication tokens, provider access controls, and signed course packages. Access to support messages and service administration is restricted to authorised people. No online service can guarantee absolute security.
11. Children
TuringLingo is not directed to children under 16. We do not knowingly rely on a child's consent for optional data processing. If you believe a child has provided personal data improperly, contact us so that we can investigate and remove it.
12. Changes
We will update this policy when the service, providers, or legal requirements change. Material changes will be explained clearly and, where required, communicated before they take effect. The effective date and version at the top identify the current policy.
13. Contact
Email privacy@turinglingo.com or write to Conscious Green ICT B.V., Orionstraat 38, 1033 EV Amsterdam, the Netherlands. See the GDPR for the applicable European data-protection framework.