1. Data controller
The controller is SeanKOR, Individual entrepreneur (micro-entreprise) established in France, operating the LinguExcel service. Privacy requests can be sent to skpro@gmx.com.
2. Data used by LinguExcel
| Purpose | Data | Legal basis | Retention |
|---|---|---|---|
| Accounts and security | Email address, user ID, account and authentication timestamps, security records | Performance of the service agreement and legitimate security interests | While the account is active, then deleted or restricted to legally necessary records |
| Learning and synchronization | Target language, card and deck identifiers, progress, review history, learning settings and user-imported learning material | Performance of the service agreement | While the account is active; active records are deleted with the account, subject to limited provider backup rotation |
| Payments, subscriptions, and access | Account, customer, transaction and subscription identifiers; selected plan and price; amount, currency and tax; payment and subscription status; renewal dates; accepted legal-document versions; cancellation, refund and dispute history. Paddle collects payment-method and billing details directly; LinguExcel does not receive complete card details. | Performance of the purchase contract, legal obligations and fraud prevention | For the statutory accounting and legal retention periods; subscription records are retained while needed to manage access and lifetime-entitlement records while needed to honor that access |
| Optional product analytics | Anonymous or account identifier, session, pages, acquisition campaign, platform, learning activity, language, deck and card identifiers, active time, feature use and technical errors. Sentence text, translations and email addresses are excluded from analytics events. | Consent | No longer than 25 months for identifiable event data; aggregate statistics may be retained when they no longer identify a user |
| Newsletter | Email address, consent date and subscription source | Consent | Until unsubscribe or, for an inactive prospect, no longer than three years after the last meaningful interaction |
| Support and legal requests | Contact details, messages and information necessary to handle the request | Performance of the service, legal obligations and legitimate interests | For the time needed to resolve the request and ordinarily no longer than three years afterward, unless law requires more |
3. How data is collected
Data is provided directly when you create an account, subscribe to the newsletter, contact LinguExcel or import learning material. Learning progress is generated as you use the application. Optional analytics data is generated only after you choose to allow analytics.
Required account fields are necessary to create and secure an account. Newsletter and analytics participation are optional and do not determine access to the learning service.
4. Recipients and service providers
Access is limited to what is necessary for operating LinguExcel. Current provider categories include:
- Supabase for authentication, database storage and server-side functions;
- Vercel for website hosting and delivery;
- Paddle as merchant of record and payment provider for checkout, subscription administration, customer billing portal, taxes, payment documents, fraud prevention, refunds, and transaction support;
- infrastructure providers used to deliver audio and static assets;
- an email provider when account or newsletter messages are sent;
- professional advisers or public authorities when legally necessary.
LinguExcel does not sell personal data.
5. International transfers
Some providers may process limited data outside the European Economic Area. Where required, LinguExcel relies on recognized transfer mechanisms, such as an adequacy decision or the European Commission's Standard Contractual Clauses, together with appropriate safeguards.
6. Cookies and local device storage
LinguExcel uses essential browser storage for authentication, local progress, offline use and preferences. Optional analytics storage is used only with consent. Details and controls are available in the Cookie Policy.
7. Your rights
Depending on the circumstances, you may request access, correction, deletion, restriction or portability of your data, object to processing based on legitimate interests, and withdraw consent at any time. Withdrawing consent does not affect processing that was lawful before withdrawal.
Send requests to skpro@gmx.com. Reasonable information may be requested to verify identity. You may also lodge a complaint with the CNIL or the data protection authority in your country.
8. Account deletion
You may request account deletion by email. Deleting an account removes access to synchronized progress and may permanently remove any early-user lifetime entitlement attached to that account. Active subscriptions should be canceled before deletion. LinguExcel retains the minimum transaction, subscription, and entitlement records needed to administer access, honor valid lifetime rights, meet legal obligations and, after appropriate verification, resolve billing or account issues. Certain additional limited records may be retained when required for security, legal compliance, or the establishment and defense of legal claims.
9. Security
LinguExcel uses access controls, encrypted connections, restricted database policies and authentication controls designed to protect personal data. No online service can guarantee absolute security, but suspected incidents are investigated and notified where required by law.
10. Children
LinguExcel is not designed to collect personal data from children who cannot validly consent to an online service in their country. A parent or guardian should supervise use and contact LinguExcel if a child's data may have been provided without valid authorization.
11. Policy updates
This policy may change when the service, providers or legal requirements change. Material changes will be highlighted through the website, application or account email where appropriate. The effective date is shown at the top.