Legal

Privacy Policy

Last updated: June 10, 2026

This Privacy Policy describes our policies and procedures on the collection, use and disclosure of your Personal Data when you use the Service and tells you about your privacy rights. Please read this Privacy Policy carefully to understand how we use your Personal Data, including any additional disclosures relevant to the country, region or state you are in:

  • If you are in California, please refer to the additional disclosures set out in the CCPA Privacy section below.
  • If you are in the European Economic Area, United Kingdom or Switzerland, please refer to the additional disclosures set out in the European Privacy section below.

Contact Us

If you have any questions about this Privacy Policy, you can contact us by email at support@creatorminds.ai.

The controller responsible for your Personal Data is Creatorminds GmbH, Blumenstraße 47, 70736 Fellbach, Germany. Our complete legal details (including register and authorised representative) are set out in our Impressum at https://creatorminds.ai/impressum.

Interpretation and Definitions

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

For the purposes of this Privacy Policy:

  • Account means a unique account created for you to access our Service or parts of our Service.
  • App Store Account means your account on the Apple App Store or Google Play Store.
  • Application or Service means the software program provided by the Company downloaded by you on any electronic device, named LingoFeed.
  • Business, for the purpose of the CCPA (California Consumer Privacy Act), refers to the Company as the legal entity that collects Consumers' Personal Data and determines the purposes and means of the processing of Consumers' Personal Data.
  • Company (referred to as either the "Company", "we", "us" or "our" in this Agreement) refers to Creatorminds GmbH, Blumenstraße 47, 70736 Fellbach, Germany.
  • Consumer, for the purpose of the CCPA, means a natural person who is a California resident.
  • Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
  • Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.
  • Personal Data is any information that relates to an identified or identifiable individual. For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with you.
  • Sale, for the purpose of the CCPA, means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating a Consumer's Personal Data to another business or a third party for monetary or other valuable consideration.
  • Service Provider means any natural or legal person who processes the data on behalf of the Company.
  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself.
  • You means the individual accessing or using the Service.

Collecting and Using Your Personal Data

We collect Personal Data that you provide to us when you set up an Account and use our Service. Like most online service providers, we also collect certain Usage Data about how you use our Service in order to understand how the Service is used and how we can improve it. The categories of Personal Data we collect and how we use them will depend on how you interact with us.

If you contact us about our Service, we will collect your contact details (including your name and email address) and the subject matter and content of your enquiry.

When you use our Service, we may collect the following Personal Data:

  • Profile information, such as your display name, age confirmation, and interests.
  • Language learning information, such as your native language, language learning goals and priorities, previous experience learning the target language and current proficiency level.
  • Subscription information, such as the start date and duration of the subscription and any free trial periods.
  • Purchase information, namely confirmation that you have purchased a subscription through your App Store Account.
  • Your email address.
  • Conversations with the AI tutor. Your spoken voice is transmitted in real time to a third-party speech-to-text and AI provider and is not stored by us. The transcribed text of your conversations and the AI tutor's responses are stored in our backend so that we can provide you with progress tracking and personalised lessons.
  • Your lesson plan and progress.
  • Your preferences, such as those for push notifications, app interface language and email communications.

Voice conversations and AI processing

A core feature of the Service is voice-based conversation with an AI tutor. When you speak with the tutor:

  • Your microphone audio is captured by the Application on your Device.
  • The audio is transmitted in real time to a third-party speech-to-text and AI provider for speech-to-text conversion and AI response generation.
  • The provider returns transcribed text and the AI tutor's spoken response.
  • The transcribed text and your lesson outcomes are stored in our backend so that we can show you your progress and tailor future lessons.

We do not store your raw voice recordings. Audio is transmitted to our provider solely for the purpose of real-time speech processing and is not retained by us. The provider processes the audio on our behalf as our processor and, under the terms applicable to our use of its service, does not use the audio or text content to train its generally available models. The transcribed text of your lesson is, however, stored by us as described above.

This provider may process your audio outside the European Economic Area, including in the United States. Where this occurs, the transfer is protected by appropriate safeguards as described in the "International transfers" section below (EU Standard Contractual Clauses and, where applicable, the EU–US Data Privacy Framework).

The AI tutor generates personalised feedback and proficiency assessments based on your interactions. This is automated processing, but it does not produce legal or similarly significant effects on you within the meaning of Article 22 GDPR: the output is a learning experience, not a decision about your rights, contracts, or eligibility.

Information about how you use the Service

Usage Data is collected automatically when you use the Service. It may include information such as your Device's Internet Protocol address, browser type and version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. When you access the Service via a mobile device, we may also collect the type of mobile device, your mobile device unique ID, mobile operating system and similar diagnostic data.

If you are in the European Economic Area, United Kingdom or Switzerland, other than where our use of Usage Data is strictly necessary to provide the Service, we will only collect Usage Data to the extent you give us your consent to do so.

Information from your App Store Account

We allow you to create an account and log in through your App Store Account. When you do so, we may receive information associated with your App Store Account, such as your name and email address.

Use of your Personal Data

  • To provide our Service, including its features and to tailor the Service to individual users.
  • To manage your Account as a registered user of the Service.
  • To contact you by email, SMS or push notifications regarding updates, security and informative communications related to the Service.
  • To provide you with news, special offers and general information about other goods, services and events similar to those you have already purchased or enquired about.
  • To manage your requests sent to us.
  • To measure and improve our advertising campaigns with third-party advertising partners.
  • For business transfers, such as a merger or sale of assets.
  • To analyse performance and improve the Service.

Retention of your Personal Data

The Company will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy, including to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies. Usage Data is generally retained for a shorter period, except when used to strengthen security, improve functionality or where retention is legally required.

Subscription, purchase and invoice data may be retained for up to ten years from the end of the calendar year in which the transaction occurred, in order to comply with German commercial and tax law (§ 257 HGB, § 147 AO). Raw voice audio is not retained: it is transmitted to our speech-to-text provider for real-time processing only.

Transfer of your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices in Germany and in any other places where the parties involved in the processing are located. The Company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

Disclosure of your Personal Data

We may share your Personal Data in the following situations:

  • With Service Providers to operate our backend infrastructure, manage subscriptions, provide AI speech processing, monitor and analyse the use of our Service, advertise to you after you visited our Service, process payments, and contact you.
  • For business transfers in connection with a merger, sale, financing, or acquisition.
  • With advertising optimisation partners to measure and improve our online advertising campaigns.
  • With law enforcement or for legal reasons where required.
  • With your consent for any other purpose.

Security of your Personal Data

The security of your Personal Data is important to us, but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Email Marketing

We may use your Personal Data to contact you with newsletters, marketing or promotional materials. You may opt out by following the unsubscribe link in any email we send or by contacting us.

Payments

Paid products and services within the Service are processed by third-party payment processors. We do not store payment card details.

Behavioral Advertising

We and our third-party advertising partners use Personal Data about your use of the Service to measure and optimise our online advertising campaigns. The third-party vendors we use include:

Your Privacy Choices

You can delete your account directly in the Application under Settings → Account → Delete Account. You may also request deletion by contacting us at support@creatorminds.ai or by using our account deletion request page at lingofeed.ai/deleteaccount.

When your account is deleted, we delete or anonymise the personal data associated with your account, unless we are legally required to retain certain information. Deleting the Application from your device does not, by itself, delete your account.

You may control behavioural advertising via device-level controls (Limit Ad Tracking on iOS, Opt Out of Ads Personalization on Android), the Digital Advertising Alliance, the European Interactive Digital Advertising Alliance, and the Network Advertising Initiative.

Links to Other Websites

Our Service may contain links to other websites that are not operated by us. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites.

Children's Privacy

Our Service is intended for users aged 13 and over. We do not knowingly collect personal data from anyone under the age of 13. If you are between 13 and 17, you may use the Service only with the consent of a parent or legal guardian. In accordance with Article 8 GDPR and § 22 BDSG, where we rely on consent for users under 16, that consent must be given or authorised by the holder of parental responsibility.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time. We will notify you via email and/or a prominent notice on our Service prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

CCPA Privacy

This section supplements the information in our Privacy Policy and applies solely to visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected. Within the last twelve (12) months, we may have collected the following CCPA categories: Identifiers (Yes); California Customer Records categories (Yes); Protected classification characteristics (No); Commercial information (Yes); Biometric information (No); Internet or other similar network activity (Yes); Geolocation data (approximate, from IP address — Yes); Sensory data (audio in transit only; not stored — Yes); Professional or employment-related information (No); Non-public education information (No); Inferences (inferred language proficiency and lesson preferences — Yes).

Sources. We obtain Personal Data directly from you, indirectly from you (observing activity on our Service), automatically through cookies and similar technologies, and from Service Providers.

Sale of Personal Information. To the extent our sharing with advertising and attribution partners (such as AppsFlyer, Meta, TikTok and Google Ads) constitutes a "sale" under the CCPA, the categories involved are Identifiers (hashed identifiers, mobile advertising IDs where permitted), Commercial information (installation and subscription events) and Internet activity (in-app events).

Your Rights under the CCPA include the right to notice, the right to know, the right to opt-out of the sale of Personal Data, the right to delete Personal Data, the right to correct inaccurate Personal Data, and the right not to be discriminated against for exercising your rights.

To exercise any of these rights, contact us at support@creatorminds.ai. We will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request (extendable once by a further 45 days).

"Do Not Track". Our Service does not respond to Do Not Track signals.

California's Shine the Light law. California residents with an established business relationship with us can request information once a year about sharing of Personal Data with third parties for direct marketing purposes by contacting us.

Minor users (Cal. B&P Code § 22581). California residents under 18 who are registered users may request removal of content or information they have publicly posted by contacting us with the email address associated with their account.

European Privacy

Who is responsible for your Personal Data. Creatorminds GmbH, Blumenstraße 47, 70736 Fellbach, Germany, is the controller of the Personal Data described in this Privacy Policy. Contact: support@creatorminds.ai.

Lawful bases. We rely on performance of a contract (Art. 6(1)(b) GDPR) to provide the Service, manage your subscription and account, process AI tutor conversations and store transcripts; compliance with a legal obligation (Art. 6(1)(c) GDPR) for tax and accounting under German law; legitimate interests (Art. 6(1)(f) GDPR) for communicating with users, securing the Service, direct marketing of similar own products under § 7(3) UWG, and engaging with users on social media; and your consent (Art. 6(1)(a) GDPR) for analytics, advertising and promotional emails.

How we may share Personal Data. With Service Providers (under Art. 28 GDPR data processing agreements); with advisors such as legal advisors and accountants; with advertising partners such as Meta, TikTok and Google Ads where you have consented; with purchasers and third parties in connection with a business transaction; and with law enforcement, regulators and other parties for legal reasons.

International transfers

The Personal Data we collect may be transferred to and stored in countries outside of the jurisdiction you are in, including the United States. We rely on appropriate safeguards such as European Commission adequacy decisions (including the EU–US Data Privacy Framework for certified recipients) and the EU Standard Contractual Clauses (2021/914). Personal Data processed within the European Economic Area does not require an additional transfer mechanism.

Privacy rights (EEA, UK, Switzerland)

Subject to applicable law, you have the right of access, right of portability, right to rectification, right to erasure, right to restriction of processing, right to object, and the right to withdraw consent (without affecting the lawfulness of prior processing).

To exercise one of these rights, please contact us at support@creatorminds.ai. We may ask you to provide certain information to confirm your identity.

Privacy complaints

You have the right to lodge a complaint with your national data protection authority. As our company is based in Baden-Württemberg, Germany, our competent supervisory authority is:

Landesbeauftragter für den Datenschutz und die Informationsfreiheit Baden-Württemberg (LfDI BW), Königstraße 10a, 70173 Stuttgart, Germany — baden-wuerttemberg.datenschutz.de.