Privacy Policy

Last updated: August 8, 2026

This Privacy Notice for Amorim Labs LLC (doing business as "Linguei") ("we," "us," or "our") describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

• Download and use our mobile application (Linguei), or any other application of ours that links to this Privacy Notice
• Use Linguei. This application allows users to learn languages through real-world content. Users can upload, import, record, or photograph audio, video, images, and text, or describe a topic to generate phrases with AI, and the app uses artificial intelligence to transcribe spoken language, extract text from images (OCR), translate it, generate speech audio, and create interactive learning materials such as flashcards with spaced-repetition review for vocabulary, listening, reading, and dictation practice.
• Engage with us in other related ways, including any customer support, marketing, or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at support@linguei.com.

Summary of Key Points

Table of Contents

1. What Information Do We Collect?
2. How Do We Process Your Information?
3. What Legal Bases Do We Rely On?
4. When and With Whom Do We Share?
5. Do We Use Advertising or Tracking?
6. Do We Offer AI-Based Products?
7. Your Responsibilities for Uploaded Content
8. International Transfers
9. How Long Do We Keep Information?
10. How Do We Keep Information Safe?
11. Do We Collect Information From Minors?
12. What Are Your Privacy Rights?
13. Do-Not-Track Features
14. US Residents' Privacy Rights
15. Brazil — LGPD
16. Updates to This Notice
17. How to Contact Us
18. Review, Update, or Delete Your Data

1. What Information Do We Collect?

Personal information you disclose to us

Content You Choose to Process. When you use the core features of the Services, you may upload, import, record, photograph, or request the following content:

• Audio and video — imported from your device or recorded through the microphone, processed to transcribe spoken language.
• Images and photos — imported from your photo library or captured with the camera, processed solely to extract text (OCR), such as book pages, signs, or posters. OCR is performed entirely on your device: your images and photos never leave your device and are never uploaded to our server or to any third party. We do not perform facial recognition or biometric identification on any image.
• Text — typed or pasted by you, processed for translation, flashcard generation, and speech synthesis; and topic descriptions you provide to the AI phrase generator.

Audio, video, and text are transmitted temporarily to our processing server and to our AI Service Providers solely to deliver the requested feature (transcription, translation, phrase generation, speech synthesis). Images are processed entirely on your device and are never transmitted. We do not retain any submitted content on our servers after processing is complete. See Sections 6 and 9 for details.

Automatic Local Backup. Once per day, the app automatically generates a local backup file (.linguei) containing your decks, flashcards, and audio. This file is stored on your own device and is included in your device's iCloud Backup (managed by Apple under your Apple ID). We do not receive or have access to this file. See Section 9 for details.

Contact Information. If you contact us for support or feedback (for example, by email), we collect the information you provide, such as your email address and the contents of your message. The app itself does not require an account and does not ask for your name or email address.

Creator (Referral) Codes. If you choose to enter a creator's discount code in the app, we record that code together with the app-generated device identifier so that, if you later subscribe, the subscription can be attributed to that creator for commission purposes. This does not include your name or any contact information.

Sensitive Information. We do not intentionally process sensitive personal information. If content you upload happens to contain sensitive information, it is processed only mechanically to provide the requested feature and is not retained or used to draw inferences about you.

Payment Data. All purchases (the Linguei Pro subscription, in monthly or annual periods, and one-time processing credit purchases) are processed exclusively by Apple through the App Store's In-App Purchase system (StoreKit). We do not collect, access, store, or process any payment or financial information, such as credit card numbers or billing details. We receive from Apple only signed confirmations necessary to verify your subscription status, trial status, refunds, and credit purchases. All payment data is handled directly by Apple in accordance with Apple's Privacy Policy: apple.com/legal/privacy.

Application Data. If you use our application, we also may collect the following information if you choose to provide us with access or permission:

• Mobile Device Access. We may request access or permission to certain features of your mobile device, including the camera (to photograph text), photo library (to import videos and images), and microphone (to record audio). If you wish to change our access or permissions, you may do so at any time in your device's settings. Denying a permission only disables the corresponding feature; the rest of the app remains usable.
• Push Notifications. We may request to send you notifications for spaced-repetition review reminders and app-related features. Notification schedules are generated locally on your device based on your study preferences; we do not monitor whether or when you open those notifications. You may turn notifications off at any time in your device's settings.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

We automatically collect certain information when you use the Services. This information does not reveal your specific identity (like your name) but may include:

• Device Identifier. An identifier generated by the app and stored securely on your device, used to authenticate requests to our processing server, to enforce per-device usage allowances and credit balances, and to prevent abuse. We do not collect your device's advertising identifier (IDFA).
• Log and Usage Data. Service-related, diagnostic, usage, and performance information our systems automatically collect, such as date/time stamps of feature usage, tokens consumed per request, error reports, and request metadata (for example, IP address as part of standard server logs).
• Device Data. Information about the phone or tablet you use, such as hardware model, operating system version, language preferences, and system configuration.
• Crash and Diagnostic Data. Provided to us by Apple in aggregated or pseudonymized form when you have opted in to share analytics with app developers in your iOS settings.

This information is needed to maintain the security and operation of the Services, to enforce usage allowances, and for our internal analytics and reporting purposes.

2. How Do We Process Your Information?

• To deliver and facilitate delivery of Services. Transcribing audio, extracting text from images (on device), translating text, generating flashcards, phrases, and speech audio, and delivering spaced-repetition review notifications at the times you configure.
• To verify purchases and entitlements. Checking, via signed Apple confirmations, whether you hold an active Linguei Pro subscription (including whether you are in a free trial), and crediting and tracking one-time processing credit purchases.
• To operate our creator program. When you enter a creator's code, associating that code with your device identifier so a resulting subscription can be attributed to the creator for commission purposes.
• To prevent abuse and protect our Services. Enforcing per-device processing allowances, fraud monitoring, and keeping the Services safe and secure.
• To identify usage trends. Understanding how the Services are used, in aggregate, so we can improve them.
• To respond to your inquiries. Providing customer support when you contact us.
• To comply with legal obligations. Responding to lawful requests and legal process, and protecting our rights.
• To save or protect an individual's vital interest. Such as to prevent harm.

We do NOT use your information to: train artificial intelligence models, build personality or behavioral profiles about you, show you advertising, sell your data to third parties, or send you marketing emails (we do not collect your email address through the app).

3. What Legal Bases Do We Rely On to Process Your Personal Information?

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases:

• Consent. We process your information where you have given us permission for a specific purpose — for example, access to your camera, microphone, or photo library, or permission to send notifications. You can withdraw your consent at any time (see Section 12).
• Performance of a Contract. We process your personal information when necessary to fulfill our contractual obligations to you — for example, processing the content you submit in order to deliver transcription, translation, phrase generation, and speech synthesis, and verifying your purchases to unlock what you paid for.
• Legitimate Interests. We may process your information when reasonably necessary to achieve our legitimate business interests where those interests do not outweigh your interests and fundamental rights and freedoms — for example, to enforce per-device usage allowances and prevent fraud and abuse, diagnose problems and maintain the security of the Services, analyze aggregate usage to improve the Services, and operate our creator commission program.
• Legal Obligations. We may process your information where necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital Interests. We may process your information where necessary to protect your vital interests or the vital interests of a third party.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (implied consent). You can withdraw your consent at any time. In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example: if collection is clearly in the interests of an individual and consent cannot be obtained in a timely way; for investigations and fraud detection and prevention; for business transactions provided certain conditions are met; if it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim; for identifying injured, ill, or deceased persons and communicating with next of kin; if we have reasonable grounds to believe an individual has been, is, or may be a victim of financial abuse; if it is reasonable to expect collection and use with consent would compromise the availability or accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province; if disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records; if it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced; if the collection is solely for journalistic, artistic, or literary purposes; or if the information is publicly available and is specified by the regulations.

4. When and With Whom Do We Share Your Personal Information?

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work. These third parties are contractually restricted from using your personal information for any purpose other than providing services to us. The specific third parties we currently work with are:

Each partner has its own privacy policy, which we encourage you to review: OpenAI · Groq · Apple · Cloudflare · MiniMax (available on the provider's website).

We also may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. In such an event, the successor will remain bound by the commitments of this Privacy Notice or will notify you of any material changes.
• Legal Requirements. We may disclose information where required by law, subpoena, court order, or other legal process, or where we believe in good faith that disclosure is necessary to protect our rights, your safety or the safety of others, to investigate fraud, or to respond to a government request.

5. Do We Use Advertising or Tracking Technologies?

Linguei contains no advertising. We do not use advertising SDKs, we do not request the App Tracking Transparency permission, we do not collect or use your device's advertising identifier (IDFA), and we do not track you across other companies' apps or websites. Linguei is a native mobile app and does not use browser cookies.

If we ever introduce advertising in a future version, we will update this Privacy Notice first, and any tracking for advertising purposes would only occur with your explicit permission through Apple's App Tracking Transparency framework.

6. Do We Offer Artificial Intelligence-Based Products?

As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, "AI Products"). The terms in this Privacy Notice govern your use of the AI Products within our Services.

Use of AI Technologies

We provide the AI Products through third-party service providers ("AI Service Providers"), currently OpenAI, Groq, and MiniMax, accessed via our own processing server hosted on Cloudflare Workers. Your submitted content will be shared with and processed by these AI Service Providers solely to enable the features you request. You must not use the AI Products in any way that violates the terms or policies of any AI Service Provider.

Our AI Products

• Audio transcription (including audio you record through your device's microphone or import from videos)
• Optical character recognition (OCR) — extracting text from images and photos you provide. OCR is performed entirely on your device using Apple's built-in Vision framework: your images and photos are never uploaded to our server or to any AI Service Provider. Only the text extracted from the image is transmitted for translation. We do not perform facial recognition or biometric identification.
• Translation of transcribed or typed text
• Generation of learning materials such as flashcards, example phrases from a topic you describe, and phrase variations
• Speech synthesis (text-to-speech) — generating the audio for your flashcards, including slow-speed versions, on our servers via our AI Service Providers

How We Process Your Data Using AI

Audio and text you submit are transmitted over encrypted connections to our processing server, which routes them to the appropriate AI Service Provider, returns the result to your device, and discards the content. Images are processed entirely on your device and are never transmitted. Content is not linked to your identity, is not retained by us after processing, and — under the API terms of our AI Service Providers — is not used to train their models.

Accuracy Disclaimer

AI-generated outputs (transcriptions, OCR text, translations, generated phrases, synthesized audio) are produced automatically and may contain errors or inaccuracies. They are provided for language-learning purposes only and should not be relied upon for any purpose where accuracy is critical.

How to Opt Out

Our AI-based features only process content when you voluntarily upload, import, record, photograph, type, or request it within the app. No content is processed without your direct action. You can opt out of AI processing at any time simply by not submitting content. If you have any questions about opting out, contact us at support@linguei.com.

7. Your Responsibilities Regarding Content You Upload

By submitting content (audio, video, images, or text) for processing, you represent and warrant that: you have the legal right to use and process that content, including any necessary rights, licenses, or permissions from third parties whose voice, image, likeness, or intellectual property may appear in the content; your submission and our processing of the content as described in this Privacy Notice does not violate any applicable law or the rights of any third party; and you will not submit content containing the personal information of others without a lawful basis to do so.

Third-Party Content. When you import content originating from third-party platforms (such as TikTok, Instagram, YouTube, or similar services), Linguei processes only the copy of the content that you choose to provide from your own device. We do not access, connect to, or retrieve content from these platforms on your behalf. We are not affiliated with or endorsed by these platforms, and your use of their content must comply with their respective terms of service and applicable copyright laws. You are solely responsible for ensuring that your import and use of such content is lawful.

Backups and Exports. Any backup files exported manually by you through the app's backup/export function are your responsibility and are stored only in the locations you choose. We do not receive, store, or have access to your backup files — whether created automatically on your device or exported manually by you (see Section 9).

We act solely as a processor of the content you choose to submit, for the sole purpose of delivering the app's features to you. We do not review, moderate, or monitor the content you process, and we disclaim responsibility for the content users choose to submit, to the maximum extent permitted by applicable law.

8. Is Your Information Transferred Internationally?

Our processing infrastructure and our service providers are located primarily in the United States. Regardless of your location, please be aware that your information may be transferred to, stored by, and processed in the United States and other countries where our third-party providers operate.

If you are a resident of the European Economic Area (EEA), United Kingdom (UK), or Switzerland, these countries may not have data protection laws as comprehensive as those in your country. However, we take measures to protect your personal information in accordance with this Privacy Notice and applicable law.

European Commission's Standard Contractual Clauses: Where required, transfers of personal information from the EEA, UK, or Switzerland rely on appropriate safeguards, including the European Commission's Standard Contractual Clauses (and the UK Addendum, where applicable) implemented between us and our third-party providers, or on our providers' own certified transfer mechanisms (such as the EU–U.S. Data Privacy Framework, where a provider is certified). Further details can be provided upon request.

9. How Long Do We Keep Your Information?

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

Where your data lives

• On your device: all of your decks, flashcards, audio clips, and settings are stored locally on your iPhone or iPad, inside the app's sandbox (protected by iOS).
• On our server: only during immediate processing (typically seconds to a few minutes). After transcription, translation, generation, or speech synthesis is complete, the files are discarded. We do not keep a history of what you have processed.

Automatic daily backup (on your device)

Once per day, Linguei automatically generates a backup file on your device containing all of your decks, flashcards, and audio in a single archive.

Why we do this: individual audio files are intentionally marked to be excluded from iCloud Backup. This protects against a known iOS behavior that can silently delete such files when the device runs low on storage — but it also means that, without a backup, your audio would not survive a device restore. The daily backup file solves this: because it is stored in the app's Documents folder (which is included in your iCloud device backup), it is restored automatically when you set up a new device from an iCloud Backup.

Restoring: when you open Linguei on a new device (after restoring from iCloud Backup), the app automatically detects the backup file and offers to restore it. One tap brings back your decks, cards, and audio.

Important: this backup file never leaves your device except as part of your own iCloud device backup, which is created and managed entirely by Apple under your Apple ID and Apple's Privacy Policy. We have no access to your iCloud Backup or its contents.

Manual backup (optional)

You can also export a backup at any time via the app's backup settings. This generates the same type of backup file, which you may save wherever you choose (iCloud Drive, Google Drive, AirDrop, email to yourself, etc.). Any manually exported backup files are your responsibility and are stored only in the locations you choose; we do not receive or have access to them.

Cross-device sync

Linguei does not automatically sync your decks between multiple devices in real time. If you use an iPhone and an iPad, you must export a backup on one device and restore it on the other. We are evaluating adding sync or cloud backup in a future update; if we do, this Privacy Notice will be updated accordingly before the feature launches.

Retention and deletion

• Your local data exists for as long as Linguei is installed. If you uninstall the app, all locally stored data is deleted by iOS. (Copies inside your own iCloud device backup remain under your control through your Apple ID and Apple's backup settings.)
• You can delete individual decks within the app at any time.
• Content sent to our server for processing is not retained after the result is returned to your device.
• Allowance and purchase records associated with the app-generated device identifier (tokens consumed, credit balance, subscription/trial status, creator-code attribution) are retained for as long as needed to operate the Services, account for creator commissions, and handle refunds, and are then deleted or anonymized.
• Server logs (device identifiers, timestamps, request metadata) are retained for a short period necessary for security, abuse prevention, and diagnostics, and then deleted or anonymized.
• Support emails are retained as long as needed to resolve your inquiry and for our legitimate record-keeping.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because it has been stored in backup archives), we will securely store it and isolate it from any further processing until deletion is possible.

10. How Do We Keep Your Information Safe?

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process, including encrypted transmission (TLS/HTTPS) between your device, our server, and our service providers, and a data-minimization architecture in which content is not retained after processing and learning materials remain on your device.

However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

11. Do We Collect Information From Minors?

Linguei is not directed at children under 13 years of age (or the equivalent minimum age in your jurisdiction), and we do not knowingly collect, solicit, or process personal information from children under 13, nor do we knowingly sell or share such information.

By using the Services, you represent that you are at least 18 years of age or the age of legal majority in your jurisdiction, or that you are the parent or legal guardian of a minor of at least 13 years of age and consent to, and supervise, such minor's use of the Services.

If we learn that personal information from a child under 13 (or the equivalent minimum age in your jurisdiction) has been collected, we will take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children, please contact us at support@linguei.com.

12. What Are Your Privacy Rights?

In some regions (like the EEA, UK, Switzerland, Canada, and Brazil), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure, (iii) to restrict the processing of your personal information, (iv) if applicable, to data portability, and (v) not to be subject to automated decision-making. If a decision that produces legal or similarly significant effects is made solely by automated means, we will inform you, explain the main factors, and offer a simple way to request human review. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us using the details in Section 17.

We will consider and act upon any request in accordance with applicable data protection laws. If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you have the right to complain to your Member State data protection authority or the UK data protection authority. If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time — for example:

• Camera, Photos, Microphone: iOS Settings → Privacy & Security → select the category → disable for Linguei.
• Notifications: iOS Settings → Notifications → Linguei → off.

Withdrawal will not affect the lawfulness of processing before its withdrawal nor, where applicable law allows, processing conducted in reliance on lawful grounds other than consent.

Practical self-service controls:

• Access your data: your decks and cards are stored on your device — you can view them in the app at any time.
• Delete your data: delete decks within the app or uninstall Linguei; all locally stored data is removed. Copies inside your own iCloud device backup remain under your control through your Apple ID and Apple's backup settings.
• Cancel your subscription: iOS Settings → your Apple ID → Subscriptions → Linguei Pro → Cancel.

If you have questions or comments about your privacy rights, you may email us at support@linguei.com.

13. Controls for Do-Not-Track Features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized, and we do not currently respond to DNT browser signals. In any case, Linguei performs no cross-app or cross-site tracking of any kind. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is no industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

14. Do United States Residents Have Specific Privacy Rights?

Categories of Personal Information We Collect

The table below shows the categories of personal information we have collected in the past twelve (12) months (or, if the app has been available for less than twelve months, since launch). The table includes illustrative examples and does not necessarily reflect every type of personal information collected. For a comprehensive inventory, please refer to Section 1.

We will use and retain the collected personal information as needed to provide the Services or as follows: Category A — device identifiers are retained while needed to enforce allowances and prevent abuse; server logs are short-lived and then deleted or anonymized. Category D — entitlement status is verified via signed, Apple-issued confirmations transmitted with processing requests solely to verify your plan; allowance and credit records are retained while needed to operate the Services and account for refunds and creator commissions. Category F — usage data is retained in aggregate for analytics. Category H — audio and video are processed in real time for transcription and translation purposes and are not retained by us; once the materials are generated, the original media is discarded from our systems.

Will your information be shared with anyone else?

We may disclose your personal information to our service providers pursuant to written contracts, as described in Section 4. We do not sell personal information, and we do not share personal information for cross-context behavioral (targeted) advertising. We have not sold or shared personal information of consumers, including consumers we know to be under 16 years of age. In the preceding twelve (12) months, we have disclosed the following categories to third parties for a business purpose only: Category A (device identifier, to our cloud infrastructure provider); Category D (signed entitlement confirmations, to our cloud infrastructure provider); Category H (audio and text, to our AI Service Providers and cloud infrastructure provider, for processing only; images are not disclosed to anyone, as OCR runs on-device).

Your Rights

You have rights under certain US state data protection laws. These rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include: the right to know whether or not we are processing your personal data; the right to access your personal data; the right to correct inaccuracies in your personal data; the right to request the deletion of your personal data; the right to obtain a copy of the personal data you previously shared with us; the right to non-discrimination for exercising your rights; and the right to opt out of the processing of your personal data for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (we do not engage in any of these practices).

Depending upon the state where you live, you may also have: the right to access the categories of personal data being processed (including under Minnesota law); the right to obtain a list of the categories of third parties to which we have disclosed personal data (including under California, Delaware, and Maryland law); the right to obtain a list of specific third parties to which we have disclosed personal data (including under Minnesota and Oregon law); the right to review, understand, question, and, depending on where you live, correct how personal data has been profiled (including under Connecticut and Minnesota law); the right to limit use and disclosure of sensitive personal data (including under California law); and the right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (including under Florida law — note that we do not operate voice or facial recognition features; audio is transcribed to text, not used to identify you).

Please note that because we do not collect your name, email, or account information through the app, and the content you process is not retained or linked to your identity, in many cases we hold no personal information that can be associated with you — meaning there may be nothing for us to access, correct, or delete beyond what resides on your own device under your control.

How to Exercise Your Rights

To exercise these rights, you can contact us by emailing us at support@linguei.com, or by referring to the contact details at the bottom of this document. Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. If we cannot verify your identity from the information already maintained by us, we may request additional information for verification, security, or fraud-prevention purposes. Given our data-minimization architecture, in some cases verification may not be possible because we hold no identifying information about you; in such cases we will explain this in our response. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request, and the agent will need to provide written and signed permission from you.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at support@linguei.com. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decision. If your appeal is denied, you may submit a complaint to your state attorney general.

California "Shine The Light" Law

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit it in writing using the contact details in Section 17. We do not disclose personal information to third parties for their own direct marketing purposes.

15. Do Other Regions Have Specific Privacy Rights? (Brazil — LGPD)

If you are a resident of Brazil or your personal data is collected in Brazil, the processing of that information is also governed by Law No. 13.709/2018 (Lei Geral de Proteção de Dados Pessoais – LGPD).

Under the LGPD, you have the right to: confirm the existence of processing of your data; access your data; correct incomplete, inaccurate, or outdated data; request the anonymization, blocking, or deletion of unnecessary data or data processed in non-compliance with the law; request the portability of your data; obtain information about the public and private entities with which we share your data; be informed about the possibility of not providing consent and the consequences of refusal; and revoke your consent at any time.

The legal bases we rely on under the LGPD correspond to those described in Section 3, including consent (Art. 7, I), performance of a contract (Art. 7, V), legitimate interest (Art. 7, IX), and compliance with legal obligations (Art. 7, II).

To exercise any of these rights, please contact us at the email provided in this Privacy Notice. The authority responsible for enforcing the LGPD in Brazil is the National Data Protection Authority (Autoridade Nacional de Proteção de Dados – ANPD), to which you may also submit complaints.

16. Do We Make Updates to This Notice?

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Last updated" date at the top of this Privacy Notice. If we make material changes, we may notify you either by prominently posting a notice of such changes within the app or by other reasonable means. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

17. How Can You Contact Us About This Notice?

If you have questions or comments about this notice, you may contact us by email at support@linguei.com, or by post at:

Amorim Labs LLC
Attn: Privacy
100 Kings Point Dr, Apt 1618
Sunny Isles Beach, FL 33160
United States

18. How Can You Review, Update, or Delete the Data We Collect From You?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.

Because of Linguei's design, most of your data lives on your own device: you can review it in the app, delete decks individually, or remove everything by uninstalling the app. Content sent to our servers is discarded after processing and is not linked to your identity, so in most cases we retain nothing about you to delete.

To submit a request to review, update, or delete your personal information, please contact us at support@linguei.com.