1. Data controller
VOLUMEXATO – LDA, NIF 519621980, Av. Infante D. Henrique, 107, 2.º Dto., 2730-100 Barcarena, Portugal. Contact: [email protected].
2. Data we collect
Account data: name, email address and password (stored encrypted).
Learning data: selected languages, level, exercise results, progress, and the text or voice recordings you submit to practice with the AI tutor.
Purchase data: plan purchased, date and amount. Card details are handled directly by our payment provider and are never stored by us.
Technical data: IP address, device and browser type, and usage logs needed to operate and secure the service.
3. Why we use it (legal bases)
To provide the service and your purchased plan (performance of contract).
To personalise lessons and measure progress (performance of contract).
To keep the service secure and prevent abuse (legitimate interest).
To meet accounting and tax obligations (legal obligation).
To send marketing emails, only if you opt in (consent, which you can withdraw anytime).
4. AI processing
Your practice messages and voice recordings are processed by AI providers acting on our behalf solely to generate tutoring responses and feedback. They are not used to make decisions with legal effects about you.
5. Sharing
We share data only with service providers that help us run Fundly Languages (hosting, AI processing, payments, email), bound by data processing agreements, or when required by law. We do not sell your personal data.
6. International transfers
Where providers are located outside the European Economic Area, transfers are protected by adequacy decisions or Standard Contractual Clauses.
7. Retention
Account and learning data are kept while your account exists and deleted within 90 days after you close it. Voice recordings are kept only as long as needed to provide feedback. Billing records are kept for the period required by Portuguese tax law (10 years).
8. Your rights
You may request access, rectification, erasure, restriction, portability, or object to processing by writing to [email protected]. You also have the right to lodge a complaint with the Comissão Nacional de Proteção de Dados (CNPD – www.cnpd.pt).
9. Security
We use encryption in transit, access controls and regular reviews to protect your data.
10. Children
The service is not intended for children under 16 without parental consent.
11. Changes
We will post any updates on this page and notify registered users of material changes.