ChegouLisboa is a European Portuguese learning app made by an independent developer ("we"). This policy explains, in plain language, what data the app processes, why, and what control you have. Short version: we collect the minimum needed to run the app, your audio never leaves your device, your typed translations are never stored under your name, and everything lives on servers in the European Union.
What we process, and why
1. Your account
When you sign in with Apple or Google we receive your name, email address, and a sign-in identifier from that provider. We use it to create your account and sync your data across devices. Legal basis: performing the service you signed up for (GDPR Art. 6(1)(b)).
2. Learning progress
Your study progress (reviewed words and sentences, streaks, XP, lesson completion, pronunciation scores computed on your device) syncs to your account so it survives reinstalls and works across devices. Legal basis: Art. 6(1)(b).
3. Saved phrases and bookmarks
Phrases and bookmarks you save are stored on your account to sync across devices. Items you delete are removed from all your devices, and everything is permanently erased when you delete your account. Legal basis: Art. 6(1)(b).
4. Translation
When you use the translator, the text you typed is sent to our server in the EU and forwarded to Microsoft Azure AI Translator (our translation provider, processed in Microsoft's West Europe region) solely to perform the translation you requested. Your text is not stored under your account and not used to train any AI models. So that repeated requests are answered instantly, the returned translation may be kept for up to 30 days in a server cache that is keyed by an irreversible fingerprint of the phrase and linked to no user or device. Frequently requested phrases may be counted anonymously to help us decide which official lessons to build next: a phrase is only recorded after it has been requested from at least 5 different devices, is never linked to any user or device, and is not counted at all if you have turned off usage analytics. Legal basis: Art. 6(1)(b) for the translation; Art. 6(1)(f) for the anonymous phrase counts.
5. Speech and pronunciation — on your device only
Pronunciation practice is scored by speech recognition running entirely on your device. Your voice is never recorded to our servers and no audio ever leaves your phone.
6. Usage analytics (optional)
To understand which features help learners, the app can send usage events (e.g. "a lesson was completed", "the translator was used") tagged with a random device identifier and — when you are signed in — your account ID, so usage counts correctly across your devices. These events contain no name, no email, no typed or spoken content, and are never used for advertising or profiling. You can turn this off — or erase what was collected — anytime in Settings → Privacy. Analytics data is automatically deleted after 13 months. Legal basis: Art. 6(1)(f) (legitimate interest in improving the app), with your right to object honored instantly via the in-app toggle.
7. Purchases
Subscriptions and purchases are processed by Apple (payment) and RevenueCat (receipt validation). We never see your payment details; we store only your subscription status (e.g. "premium until date X") to unlock features. Legal basis: Art. 6(1)(b).
8. Crash reports
If the app crashes, a technical report (device model, OS version, what the code was doing) is sent to our self-hosted error tracker on our own EU server. Crash reports contain no learning content or typed text. Legal basis: Art. 6(1)(f).
Who we share data with (sub-processors)
We use no advertising networks and never sell or share your data for advertising. The only services that touch data, each strictly for the purpose shown:
| Service | Purpose | Where |
|---|---|---|
| Microsoft Azure AI Translator | Performs translations you request | EU (West Europe) |
| Apple / Google | Sign-in; Apple also processes payments | Per their policies |
| RevenueCat | Validates purchase receipts | USA (EU–U.S. Data Privacy Framework participant) |
| Hetzner | Hosts our servers and database | Germany (EU) |
| Bunny CDN | Delivers course audio files (standard web logs only) | EU edge servers |
Your rights and the buttons that exercise them
| Right | How |
|---|---|
| See / export your data (Art. 15/20) | In-app, or email us — we provide a full machine-readable export of your account and saved content |
| Delete everything (Art. 17) | Settings → Delete Account — immediately and permanently erases your account, progress, and saved content from our servers |
| Stop analytics (Art. 21) | Settings → Privacy → Share anonymous usage data toggle |
| Erase analytics (Art. 17) | Settings → Privacy → Erase analytics data |
| Complain | You may lodge a complaint with your data-protection authority (in Portugal: CNPD, cnpd.pt) |
Anything else — email support@chegoulisboa.app. We answer within 30 days as GDPR requires, usually much faster.
Retention
| Data | Kept |
|---|---|
| Account, progress, saved content | Until you delete your account (then erased immediately) |
| Translation text | Not stored under any account; cached translations (keyed by an irreversible phrase fingerprint) expire after 30 days |
| Usage analytics | 13 months, then automatically deleted |
| Encrypted backups | Rotated on a fixed schedule (days–months); deleted data ages out with the rotation |
Children
ChegouLisboa is not directed at children under 16 and we do not knowingly process their data.
Changes
If this policy changes materially, we will note it in the app before the change takes effect. The current version always lives at chegoulisboa.app/privacy.