Privacy Policy & Terms
Below is the combined Privacy Policy and Terms of Service for the Spiko mobile application.
Last updated: 19 April 2026
This document contains two parts:
- Privacy Policy — how Spiko collects, uses, and protects personal data, in compliance with the EU General Data Protection Regulation (Regulation (EU) 2016/679, “GDPR”).
- Terms of Service — the rules that govern your use of the Spiko mobile application.
By installing, accessing, or using Spiko, you agree to both.
Part 1 — Privacy Policy
1. Data Controller
The data controller responsible for your personal data is:
- Name: Spiko
- Email: spikoapp@gmail.com
- EU representative (Art. 27 GDPR): not applicable
- Data Protection Officer: not appointed — contact spikoapp@gmail.com
References to “we”, “us”, or “Spiko” mean the controller above. References to “you” mean the user of the application.
2. Scope
This Privacy Policy applies to personal data processed through the Spiko mobile application for Android (the “App”) and any related backend services. It does not cover third-party websites or services you reach through links inside the App.
3. Categories of Personal Data We Process
| Category | Examples | Source |
|---|---|---|
| Account data | Email address, username, hashed password | Provided by you at sign-up |
| Learning data | Lesson progress, streaks, hearts, exercise answers, vocabulary mastery | Generated while you use the App |
| App settings | Chosen interface language, notification preferences | Provided by you |
| Device & technical data | Device model, OS version, app version, crash logs, anonymous usage events | Collected automatically |
| Push-notification tokens | Firebase / Expo push token | Collected only if you enable notifications |
| Advertising identifiers | Google Advertising ID, if you allow ads tracking | Collected only if you consent via the OS prompt |
We do not intentionally collect special categories of personal data (Art. 9 GDPR) such as health, religion, or political opinions.
4. Purposes and Legal Bases (Art. 6 GDPR)
| Purpose | Legal basis |
|---|---|
| Creating and maintaining your account | Contract (Art. 6(1)(b)) |
| Delivering lessons, saving progress, syncing across devices | Contract (Art. 6(1)(b)) |
| Sending daily reminders and re-engagement notifications | Consent (Art. 6(1)(a)) — revocable any time |
| Diagnosing crashes and improving stability | Legitimate interest (Art. 6(1)(f)) |
| Serving advertising in the free tier | Consent (Art. 6(1)(a)) via the OS tracking prompt |
Where processing is based on consent, you may withdraw it at any time from the Profile screen or by emailing spikoapp@gmail.com.
5. Recipients and Processors
We share your personal data only with the following processors under Art. 28 GDPR:
- Supabase Inc. — authentication, hosted database, and file storage.
- Google Ireland Limited — Google AdMob (if ads are shown) and Firebase Cloud Messaging (if you enable push notifications).
- Expo / Amazon Web Services (AWS) — push-notification delivery and app infrastructure.
- Google LLC — app distribution via Google Play.
We do not sell your personal data.
6. International Data Transfers
Some processors are established outside the European Economic Area (EEA). When personal data is transferred outside the EEA, we rely on the Standard Contractual Clauses adopted by the European Commission (Art. 46 GDPR) and/or the EU–U.S. Data Privacy Framework where the processor is certified.
7. Retention
- Account and learning data — kept for as long as your account exists. If your account is inactive for more than 24 months we may delete it after a reminder email.
- Crash logs and diagnostic data — kept for up to 90 days.
- Support emails — kept for up to 24 months after the case is closed.
When retention ends we delete or irreversibly anonymise the data.
8. Your Rights (Art. 15–22 GDPR)
You have the right to:
- Access the personal data we hold about you and receive a copy;
- Rectify inaccurate or incomplete data;
- Erase your data, including by tapping Delete Account inside the App;
- Restrict or object to processing in certain situations;
- Data portability — receive your data in a structured, machine-readable format;
- Withdraw consent at any time where processing is based on consent.
To exercise any of these rights, email spikoapp@gmail.com. We reply within one month.
You also have the right to lodge a complaint with a supervisory authority in your country of residence. A list is available at edpb.europa.eu.
9. Children
Spiko is not directed at children under 14 (or 16 depending on country). If you are under that age, you may use the App only with the consent of a parent or legal guardian (Art. 8 GDPR). If we learn that we have collected data from a child without such consent, we will delete it without undue delay. Parents can contact spikoapp@gmail.com.
10. Security
We apply technical and organisational measures appropriate to the risk, including encryption in transit (TLS), encryption at rest, access controls, and regular backups. In the event of a personal-data breach likely to result in a risk to your rights we will notify the competent supervisory authority within 72 hours (Art. 33–34 GDPR).
11. Changes to This Policy
We may update this Privacy Policy from time to time. If changes are material we will notify you inside the App before they take effect. The “Last updated” date above always reflects the current version.
12. Contact
Questions or complaints about this Privacy Policy, or requests to exercise your rights, can be sent to: spikoapp@gmail.com.
Part 2 — Terms of Service
1. Agreement
These Terms of Service form a binding contract between you and Spiko (“we”, “us”, “Spiko”). By installing, accessing, or using the App, you confirm that you have read, understood, and accepted these Terms and our Privacy Policy. If you do not agree, do not use the App.
2. Eligibility
You must be at least 14 (or 16 depending on country) to create an account. If you are younger you may use the App only with verifiable consent from a parent or legal guardian.
3. Your Account
- You are responsible for the accuracy of the information you provide and for keeping your credentials confidential.
- Notify us promptly at spikoapp@gmail.com if you suspect unauthorised access to your account.
- You may use the App as a guest, in which case progress is stored only on the device and may be lost if the App is uninstalled.
- One account per person; accounts are personal and non-transferable.
4. Licence
Subject to your compliance with these Terms, we grant you a limited, non-exclusive, non-transferable, revocable, worldwide licence to install and use the App on devices you own or control, solely for your personal, non-commercial use.
5. Acceptable Use
You agree not to:
- use the App in violation of any applicable law;
- reverse-engineer, decompile, or attempt to extract the source code of the App, except to the extent permitted by law;
- scrape, copy, or redistribute our lesson content, vocabulary, audio, or translations;
- circumvent any security or anti-cheating mechanisms;
- upload content that is illegal, infringing, harassing, hateful, or sexually explicit;
- use the App to send spam, malware, or automated traffic.
We may suspend or terminate accounts that breach this section.
6. Content Ownership
The App, including its code, design, logos, lesson structure, vocabulary, audio, and translations, is owned by us or our licensors and protected by intellectual-property laws. Nothing in these Terms transfers those rights to you. If you send us feedback, you grant us a perpetual, royalty-free licence to use it.
7. Third-Party Services
The App integrates third-party services — currently including Supabase, Google AdMob, and Expo push notifications. Your use of those services may be subject to their own terms and privacy policies.
8. Advertising
The free tier of the App may display advertisements served by third-party ad networks (e.g. Google AdMob). Where required by law, we will ask for your consent before using tracking technologies for personalised advertising; otherwise, only non-personalised ads will be served.
9. Service Availability
We strive to keep the App available but do not guarantee that it will be uninterrupted, error-free, or secure. We may modify, suspend, or discontinue features at any time.
10. Disclaimers
To the maximum extent permitted by law, the App is provided “as is”, without warranties of any kind. We do not warrant that using the App will make you fluent in Italian or produce any specific educational outcome. Nothing in these Terms limits your non-waivable statutory rights as a consumer.
11. Termination
- You may stop using the App and delete your account at any time from the Profile screen or by emailing spikoapp@gmail.com.
- We may suspend or terminate your account if you materially breach these Terms or if required by law.
12. Changes to the Terms
We may update these Terms from time to time. If changes are material we will notify you in-App before they take effect. Continued use of the App after the effective date constitutes acceptance.
13. Contact
spikoapp@gmail.com