1. Introduction
FinLingo (“we”, “our”, “the App”) is operated by Apport Finance (RCS Paris 938 362 761). This policy explains how we collect, use, and protect your personal data in compliance with the EU General Data Protection Regulation (GDPR) and applicable French data protection law.
2. Data We Collect
- Account data: email address (for authentication and service communications)
- Learning progress: lessons completed, scores, streaks, and session history
- Payment data: processed exclusively by Stripe — we never access or store your card details
- Analytics data: anonymised usage patterns collected via PostHog (EU Cloud servers)
- Error monitoring: crash reports collected via Sentry for service reliability
We do not collect hardware identifiers, precise geolocation, or contacts from your device.
3. How We Use Your Data
- Provide and personalise the learning experience
- Manage accounts and authentication
- Process subscriptions and payments
- Improve the application and fix bugs
- Send service-related communications (e.g. subscription confirmations)
We do not sell, rent, or share your personal data with third parties for advertising purposes.
4. Legal Basis (GDPR Art. 6)
- Contract performance: processing necessary to provide the service you signed up for
- Legal obligations: billing data retention required by French accounting law
- Legitimate interest: service improvement, security monitoring, and fraud prevention
5. Data Sharing & Processors
We use the following third-party processors to operate FinLingo:
| Processor | Purpose | Location |
|---|---|---|
| Supabase | Database & authentication | Zurich, Switzerland (EU) |
| Stripe | Payment processing | USA (SCCs in place) |
| Vercel | Frontend hosting | USA (SCCs in place) |
| Railway | Backend hosting | USA (SCCs in place) |
| PostHog | Product analytics | EU Cloud |
| Sentry | Error monitoring | EU processing |
Standard Contractual Clauses (SCCs) are in place for all US-based processors to ensure adequate data protection for international transfers.
6. Data Retention
- Account data: retained for the duration of your subscription plus 3 years after last activity
- Billing data: 10 years (French accounting obligations)
- Progress data: deleted on request or 3 years after last activity
7. Your Rights (GDPR)
You have the right to:
- Access your personal data
- Rectify inaccurate data
- Erase your data (“right to be forgotten”)
- Export your data (data portability)
- Restrict or object to processing
To exercise any of these rights, contact us at support@finlingo.app. We will respond within 30 days.
You may also lodge a complaint with the French data protection authority: CNIL (www.cnil.fr).
8. Account Deletion
You can delete your account at any time from the app (Settings > Delete Account) or by emailing support@finlingo.app. Deletion is processed within 30 days, subject to mandatory legal retention periods for billing data.
9. Cookies & Local Storage
FinLingo does not use advertising or third-party tracking cookies. We store authentication tokens locally on your device, which are required for the service to function. Our analytics provider (PostHog) uses cookie-less, anonymised tracking on EU servers.
10. Children’s Privacy
FinLingo is intended for users aged 18 and older. We do not knowingly collect personal data from children under 16. If you believe a child has provided us with personal data, please contact us at support@finlingo.app and we will promptly delete it.
11. International Transfers
Your primary data is stored in Switzerland (Zurich) by Supabase. Some data may be processed in the United States by Stripe, Vercel, and Railway. Standard Contractual Clauses (SCCs) approved by the European Commission are in place for all US-based processors.
12. Changes to This Policy
We may update this policy from time to time. Material changes will be communicated via email to registered users. The “Last updated” date at the top of this page indicates the most recent revision.
13. Contact
For any questions about this policy or your personal data:
Email: support@finlingo.app
Entity: Apport Finance, RCS Paris 938 362 761