Privacy Policy

Updated: 22 October 2026

Paseo teaches Spanish by voice, so we handle your voice and a little technical data. Below is what, why and how to delete it, in plain words. There are no ads, no tracking across apps and no account.

1. Who is responsible for the data

[PLACEHOLDER: name or company, address and email of the data controller; take it from the Apple trader/DSA details]

For questions about data, write to support@paseospanish.com.

2. What data and why

Your spoken answers

When you answer in a lesson, the app records a short audio clip. Speech recognition is done by Apple Speech: on your device when your device and the language support it. If an answer is unclear, the app sends the short clip of that answer to our server (Cloudflare), and from there to OpenAI or, if that fails, to Google, to check the answer. To voice hints and comments, texts are also sent to these providers. We do not store the audio or the text of your answers on our server. OpenAI and Google process them under their own terms.

Voice commands ("pause", "stop", "continue") are recognised on your device.

If you turn on the experimental translation feature, its audio is handled the same way: through our server, OpenAI or Google, and not stored by us.

Problem reports (the "?" button)

If you tap "?" and send a report, we receive: your message, the lesson and step identifiers, the text of the line at that step, what the app recognised, and the app and system versions. Reports are kept in our cloud storage (Cloudflare) for as long as we need them to fix the lesson. Do not put personal data in a report.

Anonymous usage statistics

To learn which lessons help and which do not, the app sends our server three kinds of data: that the app was launched (date and build number), that you completed a lesson (lesson identifier and time), and a technical installation identifier. We never store that identifier in the clear: the server keeps only a one-way keyed hash of it, which does not point to you or your device without our secret key. The statistics contain no name, email, phone number, Apple ID, location, audio or the text of your answers. The data is used only for analytics and for improving lessons, is not shared with advertising networks and does not track you across other apps. We also count AI calls per day to protect the service from overload.

You can delete everything collected so far for this device in the app: Settings, then "Приватність" (Privacy), then "Видалити мої дані статистики" (delete my statistics data). After deletion, later launches are counted anonymously again.

Technical identifiers

• A random installation identifier is kept in the Keychain on your device (it does not sync between devices). It is used to count free lessons and the subscription.
• Apple App Attest confirms that a request comes from the genuine app. Our server receives a technical device key, not your personal data.

Subscription

Apple handles the purchase and payment. We never see payment details. To verify a subscription, our server receives signed transaction data from Apple: the transaction identifier, the product and the expiry date.

iCloud and data on your device

The app keeps the dates of completed lessons on your device and, if iCloud is on, in your iCloud (key-value storage), so progress is the same on all devices with the same Apple ID. We have no access to your iCloud. Settings, reminders and progress stay on your device. Reminders are local notifications; our server does not send them.

3. Who receives data

• Cloudflare: hosting of our server and storage (lessons, reports, statistics).
• OpenAI and Google: answer checking and voice-over, as described above.
• Apple: speech recognition, App Attest, iCloud, payments.

Some of these companies process data outside the EU. We rely on the transfer mechanisms provided by the GDPR. We do not sell data and do not pass it to advertising networks.

4. How long we keep it

• Audio and text of answers: not stored on our server.
• Anonymous statistics: as long as we use them for analytics; deleted at your request in the app.
• "?" reports: as long as needed to fix the lesson.
• Subscription data: while the subscription is active and needed to verify it.

5. Legal bases

Providing the service (answer checking, subscription): performance of our agreement with you. Microphone access: your consent, which you can withdraw in iOS Settings. Statistics and overload protection: our legitimate interest in improving and securing the service.

6. Your rights

You have the right to access, rectification, erasure, restriction of processing, data portability and objection, and the right to complain to the data protection authority in your country. You can delete the statistics of your device yourself in the app. Our data about you is not tied to a name, so to find it we may ask for technical details from your device. For other requests write to support@paseospanish.com.

7. Children

The app is not directed at children and we do not knowingly collect personal data from children. If you think a child has sent us data, write to us and we will delete it.

8. Changes

If we change this policy, we will update the date above and tell you about significant changes in the app.