Privacy Policy
Last updated: 2026-05-06
Privacy Policy
Lingo Café · lingocafe.app · read.lingocafe.app
Last updated: 6 May 2026
DRAFT — Pre-launch. Items marked
[TO CONFIRM]must be resolved before public launch.
1. Who we are
Lingo Café is operated by Marco Pegoraro, an individual based in Malmö, Sweden. References to "we", "us", or "our" in this policy refer to Marco Pegoraro as the data controller under the General Data Protection Regulation (GDPR).
Contact: marco@lingocafe.app
2. What this policy covers
This policy applies to both of our digital surfaces:
- lingocafe.app — our marketing website
- read.lingocafe.app — our web reader application
It explains what personal data we collect, why we collect it, how long we keep it, and what rights you have.
3. What data we collect and why
3.1 Marketing website (lingocafe.app)
We use Google Analytics to collect anonymised usage data: pages visited, time on page, approximate geographic region (country level), and device type. This data does not identify you personally and is used solely to understand how visitors discover and navigate the website.
Legal basis: Legitimate interests (Article 6(1)(f) GDPR) — understanding website performance.
⚠️ OPEN ITEM: Google Analytics sets cookies. A cookie consent banner is required on this surface before public launch.
3.2 Account registration (reader app)
When you create an account at read.lingocafe.app — via Google Sign-In or email and password — we collect your name, email address, and the date your account was created.
Legal basis: Contract performance (Article 6(1)(b) GDPR) — necessary to provide you with access to the service.
3.3 Language and reading preferences
During onboarding you select your native language, reading language, and reading level (CEFR). These preferences are stored to filter your book library and personalise your experience.
Legal basis: Contract performance (Article 6(1)(b) GDPR).
3.4 Reading progress and usage data
As you read, we record your position within each book and chapter. We also log technical usage data server-side, which may include session information, device type, and reading events such as chapter completions.
Legal basis: Contract performance (Article 6(1)(b) GDPR) — progress tracking is core to the reading experience.
⚠️ OPEN ITEM: The full list of server-side data points must be confirmed with the engineering team before public launch, to ensure this section accurately reflects all data collected.
3.5 Consent records
When you accept our Terms of Service, opt in to marketing communications, or join the Alpha Reader Programme, we record which consent you gave, the exact wording you agreed to, and the date and time of your action. These records are maintained for legal accountability purposes only.
Legal basis: Legal obligation (Article 6(1)(c) GDPR) — GDPR Article 5(2) accountability requirement.
3.6 Marketing communications (optional)
If you opt in, we use your email address to send you updates about new book releases and early access to features. You can withdraw this consent at any time from your Profile settings, with immediate effect.
Legal basis: Consent (Article 6(1)(a) GDPR). Withdrawal does not affect the lawfulness of processing prior to withdrawal.
3.7 Alpha Reader Programme (optional)
If you join the Alpha Reader Programme, we use your email address to send programme updates and feedback invitations, which may include short surveys, in-app prompts, NPS requests, and occasional interview invitations. Participation is voluntary and you may opt out at any time from your Profile settings.
Legal basis: Consent (Article 6(1)(a) GDPR).
3.8 Feedback and research data (Alpha Reader Programme members only)
If you participate in feedback activities — including online questionnaires, user interviews, in-app surveys, or NPS responses — we collect the responses you provide. This data is used internally for product development and growth purposes: to improve the Lingo Café experience, inform content and feature decisions, and understand how the product is being used.
Your responses are not sold or shared with third parties. Feedback data may be retained after your programme membership ends in aggregated or anonymised form. Any personally identifiable information collected through feedback activities is subject to the same retention and deletion rules as your account data, unless retention is required for legal accountability purposes.
Legal basis: Consent (Article 6(1)(a) GDPR) — captured at programme enrolment.
4. Third-party services
We use the following third-party services that process personal data on our behalf or as independent controllers:
| Service | Purpose | Location |
|---|---|---|
| Google (Sign-In) | Authentication | USA |
| Google Analytics | Website usage analytics | USA |
| Mailgun | Transactional and marketing email delivery | USA |
[HOSTING PROVIDER — TO CONFIRM] |
Application hosting | [REGION — TO CONFIRM] |
[DATABASE PROVIDER — TO CONFIRM] |
User data and reading progress storage | [REGION — TO CONFIRM] |
Google operates as an independent data controller for Google Sign-In and Google Analytics under its own privacy terms. All other providers act as data processors under agreements with us.
5. International data transfers
Several of our service providers are based in the United States. Transfers of personal data to the US are governed by the European Commission's Standard Contractual Clauses (SCCs) or equivalent approved transfer mechanisms.
You can request details of the specific transfer mechanisms in place by contacting us at privacy@lingocafe.app.
6. How long we keep your data
| Data type | Retention period |
|---|---|
| Account data and language preferences | Duration of your account; deleted within 30 days of account closure |
| Reading progress and usage data | Duration of your account; deleted within 30 days of account closure |
| Consent records | 7 years from the date of consent (legal accountability requirement) |
| Marketing communication logs | 3 years from last interaction |
| Google Analytics data | 14 months (minimum configurable setting) |
If you close your account, all personal data is deleted within 30 days, with the exception of consent records which we are required to retain for audit purposes.
7. Your rights
Under GDPR, you have the right to:
- Access — request a copy of the personal data we hold about you
- Rectification — ask us to correct inaccurate data
- Erasure — ask us to delete your data (subject to legal retention obligations)
- Restriction — ask us to limit how we process your data while a dispute is resolved
- Portability — receive your data in a structured, machine-readable format
- Objection — object to processing based on legitimate interests
- Withdraw consent — withdraw any consent you have given at any time, without affecting the lawfulness of prior processing
To exercise any of these rights, contact us at privacy@lingocafe.app. We will respond within one calendar month.
You also have the right to lodge a complaint with your national data protection authority. In Sweden, this is the Integritetsskyddsmyndigheten (IMY) — imy.se.
8. Cookies
lingocafe.app: We use Google Analytics, which sets analytics cookies to measure website traffic and usage patterns. A cookie consent banner is displayed on first visit — Google Analytics only loads after you accept. You may decline without affecting your ability to browse the site. For full details, see our Cookie Policy.
read.lingocafe.app: We use session cookies to keep you authenticated. These are strictly necessary for the service to function and do not require your consent.
9. Children
Lingo Café is intended for users aged 16 and over. We do not knowingly collect personal data from anyone under 16. If you believe we have inadvertently collected data from a child under 16, please contact us at privacy@lingocafe.app and we will delete it promptly.
10. Changes to this policy
We may update this policy from time to time. When we do, we will update the "Last updated" date at the top of this page. For material changes, we will notify you by email or in-app notification before the changes take effect.
Continued use of Lingo Café after a policy update constitutes acceptance of the revised terms.
11. Contact
Email: privacy@lingocafe.app
Data controller: Marco Pegoraro, Malmö, Sweden