Privacy Policy

This Privacy Policy explains how Golden Genius LTD ("we", "us", "our") collects, uses, and protects your information when you use the Piuma mobile application ("Piuma", the "App"). By using the App, you agree to the practices described here.

1. Information We Collect

We aim to collect as little personal data as possible. The App is designed to work without requiring you to create an account or provide your name or email.

Information you provide

• Onboarding preferences you choose in the App, such as the language you want to learn, how many words per day you want, your preferred delivery times, your selected age range, and your learning goals. A display name and profile photo are optional and stored only on your device unless you choose otherwise.

Information collected automatically

• Usage and device data: app interactions, features used, words viewed, session information, app version, device model, operating system version, language and region settings, and a device or advertising identifier.
• Approximate location: we may infer general region from your IP address or device settings. We do not collect precise GPS location.
• Diagnostics: crash reports and performance data to help us fix problems.

Subscription and purchase data

• When you start a free trial or purchase a subscription, the transaction is processed by Apple. We receive purchase and subscription-status information (for example, whether you have an active subscription or trial) through our subscription provider, RevenueCat. We do not receive or store your full payment card details — these are handled solely by Apple.

2. How We Use Your Information

• To provide and operate the App, including delivering your daily words and notifications.
• To personalise your learning experience based on the preferences you select.
• To process and manage subscriptions, free trials, and restore-purchase requests.
• To measure and improve app performance, fix bugs, and develop new features.
• To measure the effectiveness of our advertising and to show relevant ads (see Section 4).
• To comply with legal obligations and enforce our terms.

3. Push Notifications

The core function of Piuma is to deliver vocabulary to you through push notifications. If you grant notification permission, we will send you the daily words and reminders you have configured. You can disable notifications at any time in your device settings; doing so will limit the App's core functionality.

4. Advertising, Analytics, and App Tracking Transparency

We promote Piuma through advertising platforms and use analytics to understand how the App is found and used. To do this we use third-party software development kits (SDKs), including:

• Meta (Facebook) SDK — to measure the performance of our advertising campaigns on Facebook and Instagram and to attribute app installs and in-app events (such as starting a trial or subscribing) to those campaigns.
• TikTok SDK — to measure the performance of our advertising campaigns on TikTok and to attribute app installs and in-app events to those campaigns.
• Google Firebase (Cloud Storage, and analytics/crash tools) — to host the App's learning content and audio, and to collect analytics and diagnostics.
• RevenueCat — to manage subscriptions and report subscription events.
• Apple App Store / SKAdNetwork — Apple's privacy-preserving framework for measuring advertising performance.

These partners may receive a device or advertising identifier and information about your interactions with the App in order to perform attribution and measurement, and may combine it with data they hold for advertising purposes.

5. Third-Party Service Providers

The following third parties process data on our behalf or in connection with the App. Each has its own privacy policy governing its use of data:

6. Legal Bases for Processing (EEA / UK)

If you are in the European Economic Area or the United Kingdom, we process your personal data under the following legal bases under the GDPR / UK GDPR:

• Performance of a contract — to provide the App and manage your subscription.
• Legitimate interests — to improve and secure the App and understand how it is used.
• Consent — for notifications and for advertising tracking that relies on your device identifier (you may withdraw consent at any time).
• Legal obligation — where we must process data to comply with the law.

7. Data Sharing and International Transfers

We do not sell your personal data. We share data only with the service providers listed above to operate the App and our advertising. Some of these providers are located outside the UK and EEA (including the United States). Where data is transferred internationally, we rely on appropriate safeguards such as Standard Contractual Clauses or equivalent mechanisms.

8. Data Retention

Most of your preferences and learning progress are stored locally on your device and are removed when you delete the App. Subscription and analytics data held by our providers is retained only as long as necessary for the purposes described in this policy or as required by law.

9. Your Rights

Depending on where you live, you may have the right to access, correct, delete, or restrict the processing of your personal data, to object to processing, to data portability, and to withdraw consent. To exercise these rights, contact us at hello@learnpiuma.com.

California residents (CCPA/CPRA)

If you are a California resident, you have the right to know what personal information we collect, to request deletion, and to opt out of the "sale" or "sharing" of personal information for cross-context behavioral advertising. We do not sell personal information for money. To opt out of advertising-related sharing, decline the App Tracking Transparency prompt or disable tracking in your device settings, or contact us at the email above.

10. Children's Privacy

Piuma is not directed to children under the age of 13 (or the equivalent minimum age in your country), and we do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us and we will delete it.

11. Security

We use reasonable technical and organisational measures to protect your information. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will revise the "Last updated" date above and, where appropriate, notify you within the App. Your continued use of the App after changes take effect constitutes acceptance of the updated policy.

13. Contact Us

If you have any questions about this Privacy Policy or our data practices, contact us at: