Cadmora Privacy Policy

1. Scope and acceptance

This Privacy Policy applies to Cadmora and to the features available through its web and mobile versions.

By using Cadmora, you acknowledge that you have read this Privacy Policy. If you do not agree with it, you must not use the app.

2. Data controller

Controller: Cadmus Haspert Piaggio.

Privacy contact: Cadmushaspert@proton.me.

3. Categories of data we collect

Depending on how you use Cadmora, we may collect the following categories of data.

• Account data: name, email address, profile image, authentication provider, account identifiers, and sign-in information.
• Learning data: study language, UI language, selected levels, lesson progress, completed attempts, feedback, scores, saved conversations, transcripts, flashcards, SRS state, library progress, answers, preferences, XP, coins, and analytics.
• User-generated content: custom lesson prompts, scenarios, written answers, imported flashcards, notes, examples, and other content you create or submit.
• Voice and audio data: microphone input used during live roleplays and speech processing, including transcription where applicable.
• Usage data: access times, feature usage, interaction events, usage limits, plan state, and subscription-related access information.
• Device and technical data: IP address, device type, operating system, browser or WebView information, app version, crash data, diagnostics, and security logs.
• Purchase and subscription data: product identifiers, subscription status, renewal and expiration information, transaction metadata, entitlement status, and app store or RevenueCat identifiers.
• Support communications: messages, email address, issue descriptions, attachments, and any information you choose to include when contacting support.

4. How we use data

• To create, authenticate, and manage your account.
• To provide AI roleplays, transcription, lesson feedback, custom lessons, flashcards, library exercises, saved conversations, and analytics.
• To apply usage limits, plan access, subscriptions, rewards, XP, coins, and unlocks.
• To process and verify subscriptions and restore purchases where applicable.
• To personalize the experience, including UI language, learning preferences, display name, streak display, and study settings.
• To maintain security, prevent abuse, detect fraud, debug issues, and protect the service.
• To respond to support requests and service-related communications.
• To improve Cadmora, including quality analysis, reliability monitoring, and product development.
• To comply with legal obligations and enforce our Terms.

5. Legal bases

Where applicable data protection law requires a legal basis, we rely on one or more of the following bases.

• Contractual necessity: to provide the Cadmora service you request.
• Consent: for permissions or optional features where consent is required, such as microphone access or certain communications.
• Legitimate interests: to secure, maintain, analyze, and improve Cadmora, provided those interests are not overridden by your rights.
• Legal obligation: to comply with tax, accounting, consumer protection, fraud prevention, or lawful requests.

6. AI providers and processing

Cadmora may send relevant text, voice input, transcripts, lesson context, answers, and prompts to AI providers in order to generate live responses, transcriptions, feedback, explanations, custom lessons, and exercise evaluations.

We aim to send only the information reasonably necessary to provide the feature being used.

AI outputs may be stored as part of your learning history, feedback, saved conversations, flashcards, or analytics where the feature requires it.

7. Third-party services

Cadmora may share data with third-party service providers that help operate the app.

• Authentication providers, such as Google or Apple, when you choose to sign in using them.
• AI and speech processing providers, such as OpenAI or equivalent providers used to deliver language practice and feedback.
• Payment and subscription infrastructure, such as Apple in-app purchases and RevenueCat, where applicable.
• Database, hosting, logging, email, diagnostics, and infrastructure providers used to operate and secure Cadmora.
• Public authorities, courts, regulators, or legal advisors where required by law or necessary to protect rights and safety.

8. International transfers

Cadmora and its service providers may process data in countries other than your country of residence.

Where required, we rely on appropriate safeguards such as contractual protections, standard contractual clauses, or equivalent mechanisms recognized by applicable law.

9. Data retention

We keep personal data only for as long as reasonably necessary for the purposes described in this Policy, unless a longer retention period is required or permitted by law.

• Account and learning data: generally kept while your account remains active.
• Saved conversations, transcripts, flashcards, progress, and analytics: kept while your account remains active unless deleted earlier through available product controls or an account deletion request.
• Subscription and transaction records: kept as needed for billing, audit, tax, fraud prevention, app store, or legal compliance.
• Support communications: kept as needed to resolve your request and maintain service records.
• Security logs, diagnostics, and crash records: kept for a limited period necessary for security, debugging, and reliability.
• Deleted data may remain in backups for a limited period before being overwritten, unless earlier deletion is technically feasible.

10. Account deletion and data rights

You may request access, correction, deletion, restriction, objection, portability, or withdrawal of consent where these rights apply under applicable law.

You may request account deletion by contacting Cadmushaspert@proton.me. Cadmora may also provide an in-app account deletion flow where available.

We will respond to valid deletion requests within a reasonable period and generally within 30 days, unless we must retain certain information for legal, security, fraud prevention, or accounting reasons.

11. Microphone permissions

Microphone access is used only when you choose to use voice-based features such as live roleplays.

You can disable microphone access through your browser or device settings. Disabling microphone access may prevent live roleplay features from working.

12. Tracking, analytics, and advertising

Cadmora does not sell your personal data.

Cadmora does not use your data for third-party advertising or cross-app advertising tracking unless this is clearly disclosed and any required consent is obtained.

If future mobile versions use analytics or diagnostics SDKs, their data practices must be reflected in this Policy and in the relevant app store privacy disclosures.

13. Children’s privacy

Cadmora is not intended for children under 13 and does not knowingly collect personal data from children under 13.

If we learn that a child under 13 has provided personal data, we will take reasonable steps to delete it.

Users aged 13 to 17 should use Cadmora only with parental or guardian consent and supervision.

14. Security

We use reasonable technical and organizational measures to protect personal data against unauthorized access, loss, misuse, alteration, or disclosure.

No online service can guarantee absolute security. You are responsible for keeping your sign-in credentials and connected accounts secure.

15. Changes to this Policy

We may update this Privacy Policy from time to time. Material changes will be communicated through the app, by email, or by another reasonable method.

Continued use of Cadmora after the updated Policy becomes effective means that you acknowledge the updated Policy.

16. Contact

For privacy questions or requests, contact us at Cadmushaspert@proton.me.