Privacy Policy

Summary

These are the essentials. The full document below is what governs.

• We keep what Spangli needs to work: your email, your name, your country, your date of birth and your progress.
• We do not store your voice. When you practice pronunciation, the audio is transcribed and we do not store it. We do not create a voiceprint of you.
• Your answers go to artificial intelligence services that correct them. They are named in section 6.
• We do not sell your personal data. Today we do not show advertising. If we show it on the free plan, advertising based on your data will only be shown with your permission and never to people under 18.
• Your practice mistakes are stored anonymously, separately from your account and with nothing that says whose they are, to improve Spangli’s corrections. They never include accounts of people under 18.
• You can delete your account whenever you want, from the app or from the web. Everything linked to you is deleted, except the record of what you accepted, which we keep for a limited time (section 5).
• You need to meet the minimum age of your country to have an account: 13 in most countries (section 10).
• For any right, write to us at hola@spangli.app.

11. Who we are and what this policy covers

Spangli is an app for learning English, designed for Spanish speakers, owned by Orbinux LLC (“Orbinux”, “we”, “us”), a limited liability company organized under the laws of the State of Wyoming, United States.

Orbinux is the data controller for the personal data described in this policy: it decides what data is collected and why. This policy applies to the Spangli mobile app, the spangliapp.com website and related services (together, the “Service”). It is part of the Terms and Conditions.

Spangli is only available in some countries. If you connect from a country where it is not available, you will not be able to create an account.

22. What data we collect

2.1 Data you give us

2.2 Data generated when you use Spangli

• Your progress: levels, steps, points, streak, crystals, medals, your plan (Basic or Turbo) and the result of each game, with each attempt, how long you took to answer, the corrections and the help you saw.
• What the artificial intelligence decides about what you practice: its corrections, its evaluations and moderation flags (strikes).
• The record of what you accepted: the version of the Terms and of this policy you accepted, the date and your choice about promotions.
• Usage data: the screens you open, when the app goes to the background, the app version and whether you use Android or iOS.
• The notification token assigned by your phone, to send you notifications.

2.3 What we look at without storing

• Your IP address. We use it in the moment to know which country you are connecting from, because Spangli is not available in some countries and regions or to people in countries subject to United States sanctions. We do not store it.
• The sign-in attempt limit. To stop abuse we keep an encrypted code of your email and your IP, which is deleted within 2 hours at most.

2.4 The test before you create your account

Before creating an account you can take a short level test. It is anonymous: it does not ask for your name, your email or the microphone, and it does not store an identifier of your phone. It stores your answers and the test events. If you do not create the account, it is deleted within 3 days at most; if you create it, it becomes part of your account.

2.5 What we do not collect

We do not ask for identity documents, health data, your precise location, your contacts, your phone’s advertising identifier or your card details. We do not store the audio of your voice either.

33. How we use your data

The “Basis” column says what allows us to process each piece of data. In some countries the law calls it something else; your country’s annex has the details.

If we ever wanted to use your personal data for a new purpose that is not compatible with these, we would tell you first and, where the law requires it, ask for your permission.

44. Voice, artificial intelligence and automated decisions

4.1 Your voice

When you practice pronunciation or speak in a Guiada by voice:

1. The app uses the microphone only while you record.
2. The audio travels encrypted to a provider that transcribes it into text (section 6).
3. We do not store the audio. It does not stay in our database or in backups. The provider that transcribes it does not use it to train its models, but it may keep it for a time under its own terms.
4. We keep the transcript and the evaluation result, with your progress.

Orbinux does not create, store or use voiceprints or other biometric identifiers. We do not use your voice to identify you. You can remove the app’s microphone permission in your phone’s settings: the rest of Spangli keeps working.

4.2 The artificial intelligence that corrects you

To correct you and to let the characters answer you, we send artificial intelligence providers the text of what you practice and the context of the lesson. They act as data processors: they use your data only to provide that service to us, under contract, and we require them not to use it to train their own models. Accounts of people under 18 do not use OpenAI or Google Gemini.

4.3 Automated decisions

Corrections, scores, strikes and the safety filter are decided by an automated system. None of those decisions has legal effects or significantly affects you: they decide your practice within the app, not your access to the Service. If you think a strike or a block was a mistake, write to us at hola@spangli.app and a person will review it. The level the app shows you is an approximate estimate, not a certification.

4.4 Anonymous Data and our own models

Separately from accounts, we keep the mistakes made while practicing, by word and by sentence: what was asked and what was written or said in each attempt (“Anonymous Data”). Before storing them we remove everything that makes it possible to know whose they are:

• They carry no name, email, account or game identifier, or exact date (only the month).
• If an answer contains a name, a city or other personal data, it is replaced before it is stored.
• They never include data from accounts of people under 18.

We do not try to link Anonymous Data back to any person. We use it, with no time limit, to improve Spangli’s teaching, especially to train and improve our own grammar and pronunciation correction models. Your games and your progress, which are linked to your account, are not used for training.

55. How long we keep your data

66. Who we share your data with

We do not sell your personal data. We only share it in these cases.

6.1 The providers that help us provide the Service

They process your data only following our instructions and under contract.

6.2 Other cases

• Authorities: when a law or a valid order requires it, only what is requested.
• A corporate transaction: if Orbinux merges, is sold or reorganizes, your data may pass to whoever continues the Service, who remains bound by this policy. We would let you know.
• With your permission: in any other case, only if you ask us or authorize it.

6.3 Advertising

Today Spangli does not show advertising. If we show it on the free plan:

• Advertising based on your data will only be shown with your permission, which you can withdraw at any time.
• Accounts of people under 18 will never receive advertising based on their data.
• Before starting, we will update this policy with the advertising providers and let you know.

77. Transfers to other countries

Orbinux is in the United States and your data is stored there, on our providers’ servers. If you live in another country, your data travels outside it. We do this with the contractual commitments required by the law of your country: your country’s annex says which ones.

88. Your rights

Depending on the law of your country, you can:

• Know what data we have about you and ask for a copy. We send it to you in a JSON file, organized by your data and with names in words.
• Correct it. Your name, email, password and photo are changed in the app. Your country and date of birth are corrected by writing to us: the new data goes through the same check as at registration, and if with it you do not meet the minimum age of your country, or your country is not available, the account is deleted. We will not ask you for documents.
• Delete it. Delete your account in Profile or at spangliapp.com/legal/eliminar-cuenta. Everything linked to you is deleted, except what section 5 says is kept.
• Withdraw your permission for promotions, in Profile, at any time.
• Object to processing or ask us to restrict it, when the law allows you to.
• Ask for a person to review an automated decision (section 4.3).
• Complain to the data protection authority of your country (your country’s annex names it).

How to exercise them: write to us at hola@spangli.app from your account’s email. If you write from another address, we will ask you to confirm from your account’s email. We will answer within 5 business days at most (in Chile, 2 business days until November 30, 2026), unless the law of your country gives us less time. Exercising your rights is free and does not change how we treat you.

99. Security

We encrypt data in transit, store passwords encrypted, restrict access to the database by account and by function, and review access. No system is invulnerable. If an incident puts your data at risk, we will notify you and the authority when the law requires it and within the deadlines it sets.

1010. Minors

Minimum age. To have an account you need to meet the minimum age of your country: 13 in most countries; 14 in Chile, South Korea, North Macedonia, Moldova and Peru; 15 in Australia, Ecuador, Monaco and Serbia; 16 in Albania, Andorra, Bosnia and Herzegovina, Georgia, Japan, Kosovo, Mauritius, Paraguay, Rwanda, San Marino and Sri Lanka; 18 in Saudi Arabia, Algeria, Bangladesh, Bahrain, Brunei, Qatar, Colombia, Egypt, El Salvador, the Philippines, Ghana, India, Jamaica, Jordan, Oman, South Africa, Tunisia, Uganda and Zambia; and 20 in Thailand. Below that age an account cannot be created. The app asks for the date of birth without saying what the minimum age is.

Accounts of people under 18. An account of a person under 18, or of someone who accepted the Terms as a minor and has not yet accepted them as an adult, has no missions, Guiadas with artificial intelligence, pronunciation exercises or notifications; does not receive promotions or advertising based on their data; cannot buy Turbo, invite friends or upload a photo (it chooses an avatar); and its mistakes are not included in Anonymous Data. On turning 18, the app asks the person to accept the Terms as an adult.

Age from Google Play. Where the law requires it (today, Texas), the app checks your age range on Google Play. If it says you are under 18, your account is a minor’s account; if the permission of your mother, father or guardian is also missing, the account cannot be created. We only store whether Google Play says you are a minor, and only for this purpose.

If your country’s age goes up. If a new law raises the minimum age of your country, from that day no one below the new age can register, and accounts that will fall below it receive an email notice 30 days in advance and are deleted on the date of the law.

If we learn that an account does not meet the age, we suspend it and delete its data. If you are a mother, father or guardian and believe your daughter or son created an account without meeting the minimum age, write to us at hola@spangli.app.

1111. Cookies and similar technologies

The app does not use cookies or tracking pixels: it stores on your phone what is needed to keep you signed in and your preferences. The website does not use analytics or advertising cookies; it only uses a necessary cookie to keep your session on the pages that require it.

1212. Changes to this policy

We may update this policy. If the change is minor, we will notify you by email. If it is significant, we will show it to you in the app when we publish it and you will have to accept it to keep using Spangli; until you accept it, we process your data according to the version you accepted. The version and the date of the last update are at the beginning of the document.

This policy and the Terms form a single package with a single version, which is accepted in full. We keep a copy of each published version and of the version you accepted, with the date. If you want the version you accepted, write to us.

1313. Contact

Orbinux LLC 7345 W Sand Lake Rd, Ste 210, Office 6764 Orlando, FL 32819, United States

hola@spangli.app

1414. Country annexes

What the law of your country adds to this policy. If an annex says something different from the rest of the document, the annex governs for people in that country.

United States

Your rights under state privacy laws (among others, California, Colorado, Connecticut, Texas, Utah and Virginia): to know what data we collect, where it comes from and why; to ask for a copy; to correct it; to delete it; to not receive targeted advertising, to not have your data sold and to not have it used to profile you with significant effects; and to appeal if we deny a request, by writing to hola@spangli.app with the subject “Appeal”. You may act through an authorized agent, and exercising your rights does not change how we treat you.

We do not sell or share your personal data within the meaning of the California law (CCPA), we do not use it for targeted advertising and we have not done so in the last 12 months. We do not use sensitive personal data for anything that triggers the right to limit it.

California, “Shine the Light”: we do not share personal data with third parties for their own direct marketing.

Children under 13 (COPPA): the Service is not for children under 13 and we do not knowingly collect their data. If we learn that we did, we delete it.

Biometric data (Illinois, Texas, Washington and others): we do not capture, store or use biometric identifiers. The processing of your voice in section 4.1 cannot be used to identify you.

Voice recording: by accepting the Terms you consent to your voice answers being sent to our providers to correct your pronunciation (sections 4.1 and 6.1).

Canada (except Quebec)

We process your data under the Personal Information Protection and Electronic Documents Act (PIPEDA) and, in Alberta and British Columbia, their provincial laws. Spangli is not available in Quebec. We answer access requests within 30 days at most. You may complain to the Office of the Privacy Commissioner of Canada (priv.gc.ca). People aged 13 to 17 see a plain-language summary of this policy before creating their account.

Mexico: comprehensive privacy notice

• Controller: Orbinux LLC, at the address at the beginning of this policy.
• Data we process: that in section 2. We do not process sensitive personal data: the audio of your voice is transcribed, we do not store it and it is not used to identify you.
• Purposes necessary for the Service: creating and maintaining your account, giving you the lessons, correcting you, evaluating your pronunciation, providing support, preventing fraud and complying with the law.
• Purposes that are not necessary: sending you promotions, lessons, discounts and news, only if you checked the box. You can refuse or withdraw it in Profile, and that does not change the Service.
• Transfers: to the providers in section 6.1, who act as processors, and to authorities when the law requires it.
• ARCO rights (access, rectification, cancellation and objection) and withdrawal of consent: write to us at hola@spangli.app with your name, your account email, the right you want to exercise and the data concerned. We answer within 20 business days at most and, if appropriate, apply it within the following 15 business days.
• Changes to this notice: they are published on this same page and announced in the app.
• Authority: the Secretariat of Anti-Corruption and Good Governance.

Colombia: information processing policy

• Controller: Orbinux LLC, at the address and email at the beginning of this policy. Service channel: hola@spangli.app.
• Processing and purposes: we collect, store, use and delete your data for the purposes in section 3.
• Authorization: when you create your account you check the box for the Terms and this policy, which is your prior, express and informed authorization. We keep proof of that authorization.
• Your rights: to know, update, rectify and delete your data; to ask for proof of your authorization; to know how we use it; to revoke the authorization; and to file complaints with the Superintendence of Industry and Commerce (sic.gov.co).
• How to exercise them: write to us at hola@spangli.app from your account’s email, with your request. Inquiries are answered within 10 business days at most (5 more if needed, letting you know) and complaints within 15 business days at most (8 more if needed, letting you know).
• Minimum age in Colombia: 18.
• Validity: from the update date at the beginning of this policy and for as long as we process your data.

Chile

We process your data under Law 19,628 and, from December 1, 2026, Law 21,719. You have the right to access your data, rectify it, delete it and object to its processing and, from December 1, 2026, also to portability and blocking. We answer within 2 business days until November 30, 2026 and, from December 1, 2026, within 30 calendar days at most (extendable by another 30 when the law allows it). From December 1, 2026 you may complain to the Personal Data Protection Agency. Minimum age in Chile: 14.

Peru

We process your data under Law 29733 and its Regulations (Supreme Decree 016-2024-JUS). You can exercise your rights of access, rectification, cancellation and objection by writing to us: we answer access requests within 20 business days at most and the others within 10 business days at most. You may complain to the National Authority for Personal Data Protection of the Ministry of Justice and Human Rights. Minimum age in Peru: 14.

Ecuador

We process your data under the Organic Law on Personal Data Protection. You have the right to access your data, rectify it, delete it, object to its processing, to portability, to suspend its processing and not to be subject to decisions based solely on automated processes with legal effects. We answer within 15 days at most. You may complain to the Superintendence of Personal Data Protection. Minimum age in Ecuador: 15.

Argentina

We process your data under Law 25,326. We answer access requests within 10 calendar days and rectification, update or deletion requests within 5 business days.

International transfer. Your data is stored and processed outside Argentina, mainly in the United States, with the providers named in section 6. You make this possible with your express consent when you create your account (Decree 1558/2001, art. 12). You can revoke it at any time by deleting your account.

The data subject has the right to exercise the right of access to their data free of charge at intervals of no less than six months, unless a legitimate interest is proven, as established in article 14, paragraph 3 of Law 25,326.

The Agency for Access to Public Information, as the Supervisory Body of Law 25,326, has the power to handle the complaints and claims filed by those whose rights are affected by non-compliance with the rules in force on personal data protection.

Transfers to our providers in the United States are made with the model contractual clauses approved by the Argentine authority.

Switzerland

We process your data under the Federal Act on Data Protection (FADP). You have the right to information, access, rectification, deletion and to receive your data in a commonly used format. We answer within 30 days at most. Transfers to the United States are made with providers certified under the Swiss-U.S. Data Privacy Framework or with recognized contractual clauses. If your account is from Switzerland, your data does not go through OpenRouter. You may complain to the Federal Data Protection and Information Commissioner (FDPIC).

• Data controller: Orbinux LLC
• Address: 7345 W Sand Lake Rd, Ste 210, Office 6764, Orlando, FL 32819, United States
• Organized in: State of Wyoming, United States
• Privacy contact: hola@spangli.app
• Version: 2.2
• Language: this is the English version. This policy is also available in Spanish; if the two versions differ, the Spanish version governs unless the law of your country requires otherwise.

This document was drafted from the public domain templates of General Legal, PC.