Privacy policy
Who we are
Noimon Techni Monoprosopi IKE, Platonos 7, 15234 Chalandri, Greece, GEMI 181542503000, VAT EL802720904, [email protected], is the controller.
What we process and why
- Account and pass. Email, pass and payment reference, your acceptance of the terms and your withdrawal-right statement (with timestamp and terms version), sign-in codes and sessions (device type, last use), and practice progress: to provide the pass you bought (GDPR art. 6(1)(b)).
- Payment records. To meet tax law (art. 6(1)(c)), kept for the period Greek tax law requires (5 years).
- Hashed IP address and app-install ID. To limit abuse of free writing feedback (art. 6(1)(f), legitimate interest). The IP address is stored only as a keyed hash (HMAC) and deleted after 7 days. The install ID is a random number the app makes; it is stored as a hash and deleted after 12 months.
- Texts you send for writing feedback. Sent to Anthropic only to produce the feedback (art. 6(1)(b)). We do not store them.
- Page-visit statistics via Cloudflare Web Analytics, which sets no cookies.
- We count how the app is used (for example how many practice sessions start or how many purchases are made) in our own database, as daily totals. For signed-in users, the detailed records carry a pseudonymous code derived from the account with a secret key, which on its own does not lead back to your email. We use no cookies and no third parties for this, and we do not record your IP address, email, payment details or anything you write. The purpose is to improve the app (legitimate interest, GDPR art. 6(1)(f)). Detailed records are deleted after 35 days, and immediately if you delete your account. Only anonymous daily totals are kept.
If you use the app without buying, your progress stays on your device. Speaking recordings stay in your browser's memory, are never uploaded and are deleted when you leave the screen.
Who receives it (processors)
- Stripe (payments; Ireland/US)
- Resend (sign-in and receipt emails; US)
- Cloudflare (analytics and delivery; US)
- Anthropic (writing feedback; US)
- Hetzner (hosting; Germany/EU)
Transfers to the US rely on the EU-US Data Privacy Framework and/or Standard Contractual Clauses (GDPR art. 45/46).
How long
The account and progress are kept until 12 months after your pass ends, then deleted, unless you delete them earlier (Settings > Delete my account and data). Payment records are kept for 5 years, as tax law requires. Sign-in codes expire after 15 minutes and are deleted within 24 hours. Ended or expired sessions are deleted after 30 days.
Your rights
Access, rectification, erasure, restriction, portability and objection (GDPR art. 15-21). Write to [email protected]. You can complain to the Hellenic Data Protection Authority (www.dpa.gr).
No special-category data
We do not ask for nationality, ethnic origin, religion or residence status. Please do not include such information in texts you send for feedback.