Privacy Policy

1. Introduction

stickybitspecialist ("we", "us", "our"), operating Settemila Lingue, respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, and safeguard your information when you use our language learning platform at www.settemilalingue.com (the "Service").

2. Data We Collect

2.1 Information you provide

• Account information: When you sign in with Google, we receive your name, email address, and profile picture from Google.
• Learning data: Your language preferences, custom topics, study progress, and spaced repetition schedules.

2.2 Information collected automatically

• Usage data: Pages visited, features used, session duration, and interaction patterns to improve the Service.
• Device information: Browser type, operating system, screen resolution, and language settings.
• Cookies: We use essential cookies for authentication and session management, and — with your consent — analytics and advertising measurement cookies. See Section 7 for details.

2.3 Payment information

We do not directly collect or store payment card details. All payment processing is handled by Paddle, our Merchant of Record. Paddle collects and processes your payment information in accordance with their own privacy policy.

3. How We Use Your Data

We use your personal data for the following purposes and legal bases (GDPR Article 6):

3.1 Contract performance (Art. 6(1)(b) GDPR)

• Provide and maintain the Service, including personalized learning experiences
• Process your subscription and manage your account
• Generate AI-powered learning content tailored to your level and interests
• Track your study progress and optimize spaced repetition schedules
• Send essential service communications (account changes, billing)

3.2 Consent (Art. 6(1)(a) GDPR)

• Analytics cookies and usage tracking via Google Analytics (see Section 7)
• Advertising measurement cookies used to evaluate the performance of our Google Ads campaigns — so we can see which ads led people to sign up. We do not use these cookies for personalized advertising or remarketing.

3.3 Legitimate interest (Art. 6(1)(f) GDPR)

• Improve and develop new features for the Service
• Detect and prevent fraud or abuse

We do not sell your personal data to third parties. We do use measurement data, with your consent, to evaluate the performance of our Google Ads campaigns. We do not use your data for personalized advertising, remarketing, or audience targeting.

4. AI Processing

The Service uses third-party AI models to generate language learning content. When generating content for you, we may send your language preferences and topic choices to our AI providers. We do not send your name, email, or other personally identifying information to AI providers.

5. Data Sharing

We share your data only with:

• Paddle: Our payment processor and Merchant of Record, for subscription billing and invoicing.
• Google: For authentication via Google OAuth (only the data exchange necessary for sign-in), for analytics via Google Analytics 4, and — with your consent — for advertising performance measurement via Google Ads conversion tracking (see Section 7).
• AI providers: Anonymized learning context for content generation (see Section 4).
• Hosting providers: Our infrastructure providers who store and process data on our behalf, under data processing agreements.

We may also disclose your data if required by law, regulation, or legal process.

6. Data Retention

We retain your account data and learning progress for as long as your account is active. If you delete your account, we will delete your personal data within 30 days, except where we are required to retain it for legal or regulatory purposes.

Anonymized, aggregated data (which cannot identify you) may be retained indefinitely for analytics and service improvement.

7. Cookies

We use the following types of cookies:

• Essential cookies: Required for authentication, session management, and security. These cannot be disabled.
• Preference cookies: Store your language and display preferences.
• Analytics cookies: We use Google Analytics 4 (GA4) to understand how visitors use our Service. GA4 sets cookies (such as _ga) to distinguish unique users and track session information. This data is processed by Google in accordance with Google's Privacy Policy. Analytics cookies are only placed after you give consent via our cookie banner.
• Advertising measurement cookies: We run Google Ads campaigns to promote the Service. When you click one of our ads and arrive on our site, Google uses its own cookies to tell us whether that click led to a sign-up, so we can evaluate which campaigns are worth the money. Google processes this data under its Privacy Policy. These cookies are only placed after you give consent via our cookie banner.

What we do not do: We do not use your data for personalized advertising, we do not build remarketing audiences, and we do not share your data with Google to target other ads at you on third-party sites. The ad_personalization signal in Google Consent Mode remains denied even after you click Accept, so Google is not permitted to use your data for these purposes.

8. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These include encrypted data transmission (TLS), secure server infrastructure, and access controls.

However, no method of transmission over the internet is 100% secure. While we strive to protect your data, we cannot guarantee absolute security.

9. Your Rights

Under applicable data protection laws (including the GDPR), you have the right to:

• Access your personal data and receive a copy of it
• Rectify inaccurate or incomplete personal data
• Delete your personal data ("right to be forgotten")
• Restrict the processing of your personal data in certain circumstances
• Data portability: Receive your data in a structured, commonly used format
• Object to processing of your personal data in certain circumstances
• Withdraw consent at any time where processing is based on consent

To exercise any of these rights, contact us at privacy@settemilalingue.com. We will respond within 30 days.

10. International Data Transfers

Your data may be processed in countries outside the European Economic Area (EEA). In such cases, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the European Commission, to protect your data.

11. Children's Privacy

The Service is not directed at children under 16. We do not knowingly collect personal data from children under 16. If you believe we have collected data from a child under 16, please contact us and we will promptly delete it.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on this page and updating the "Last updated" date. We encourage you to review this policy periodically.

13. Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us at:

Email: privacy@settemilalingue.com

Our lead supervisory authority is the Dutch Data Protection Authority (Autoriteit Persoonsgegevens), PO Box 93374, 2509 AJ The Hague, the Netherlands (www.autoriteitpersoonsgegevens.nl). You also have the right to lodge a complaint with your local data protection authority if you believe your rights have been violated.