Privacy Policy
Version 1.2
Effective date: 15 September 2026
This Privacy Policy explains how personal data is processed when you use the LingoGap website, web application or native Android application, create or use an account, use learning or AI-assisted features, purchase or manage a subscription, contact support or otherwise interact with LingoGap.
This Policy should be read together with the LingoGap Terms and Conditions and, where relevant, the Cookie and Similar Technologies Policy.
1. Who we are and scope
LingoGap is operated and commercially provided by Uglecare ApS under licence from the relevant rights holder.
Data controller:
Uglecare ApS
CVR: 34353255
Borups Allé 116, st. tv.
2000 Frederiksberg
Denmark
Telephone: +45 91 41 20 66
Email: support@lingogap.dk
Website: https://www.lingogap.dk
Uglecare ApS is the data controller for the customer-facing processing described in this Policy, except where a third-party provider acts as a separate controller for processing that it determines independently.
This Policy covers the LingoGap website and web application, LingoGap Native Android, account and authentication services, learning features, AI-assisted features, subscriptions, support and related service operations.
2. Personal data we process
The data processed depends on how you use LingoGap.
Account and authentication data may include:
- Firebase user identifier;
- email address;
- display name and profile photograph where provided;
- authentication provider and account status; and
- account, login and relevant activity timestamps.
Learning and preference data may include:
- placement or starting level;
- lesson and section progress;
- answers and exercise state;
- writing responses and speaking transcripts;
- saved corrections and feedback;
- flashcards and review information;
- PD3-style practice attempts, answers and results;
- learning and application preferences; and
- other saved learning state needed to provide continuity.
AI-related data may include:
- text, transcripts or answers that you submit for an AI-assisted feature;
- educational context needed to provide the requested feedback;
- generated corrections, explanations, feedback or educational assessments; and
- limited usage and operational information needed for allowances, troubleshooting, security and service operation.
Subscription and billing data may include:
- selected plan and billing provider;
- subscription and entitlement status;
- subscription or transaction references;
- billing-period or renewal information where provided by the billing provider;
- cancellation, withdrawal or refund information; and
- records needed for subscription support, accounting, fraud prevention or legal obligations.
Support data may include your contact information, messages, attachments, screenshots and relevant account or billing information that you provide when requesting assistance.
Technical and security data may include authentication events, timestamps, request or error information, service identifiers, security indicators and technical metadata processed by LingoGap or its service providers.
Hosting, authentication, payment and infrastructure providers may also process IP address, browser or device information as part of normal service delivery, security and fraud-prevention operations.
The Native Android application also stores supported learner information and preferences locally on the device using application storage and local databases.
Some local data may remain only on the device, while supported data may be synchronised, backed up or sent to LingoGap services when a requested feature requires it.
3. How we obtain and use personal data
We receive personal data:
- directly from you when you create an account, submit learning content, change settings, purchase a subscription or contact support;
- automatically from your use of LingoGap where necessary to provide learning progress, authentication, service state, security and usage allowances;
- from authentication providers such as Google or Firebase when you use their authentication services;
- from Stripe for Web subscription and payment administration;
- from Google Play for Android subscription verification and administration; and
- from authorised administrators where an account or access setting is legitimately administered.
We use personal data to:
- create, authenticate and protect accounts;
- provide lessons, progress, flashcards and other learning features;
- provide requested AI-assisted corrections, feedback and assessments;
- operate PD3-style practice;
- maintain learning continuity across supported sessions and devices;
- enforce applicable service and AI usage allowances;
- verify subscriptions and provide paid access;
- process or administer cancellations, refunds and billing support;
- provide customer and technical support;
- protect LingoGap against misuse, fraud and unauthorised access;
- diagnose faults and maintain service reliability;
- comply with accounting, tax, consumer-protection and other legal obligations; and
- establish, exercise or defend legal claims.
LingoGap does not currently use personal data for behavioural advertising, personalised advertising or cross-service advertising tracking.
4. Legal bases
Depending on the processing activity, Uglecare ApS relies on one or more of the following legal bases.
Contractual necessity
We process data where necessary to provide an account or service requested by you, including learning functionality, saved progress, AI-assisted features, subscriptions, access management and support.
Legal obligations
We may process or retain information where required for matters such as accounting, taxation, consumer rights, regulatory obligations or lawful authority requests.
Legitimate interests
Where appropriate, we may process limited information for legitimate interests such as service security, fraud and abuse prevention, reliable service operation, troubleshooting, entitlement enforcement and the establishment, exercise or defence of legal claims.
Where legitimate interests are relied upon, the relevant interests and impact on users must be considered.
Consent
Where a specific optional processing activity legally requires consent, we will request that consent before carrying out that processing.
Consent may be withdrawn at any time where processing is based on consent.
Device or browser permission to use a microphone enables the requested speech-recognition feature. It does not constitute permission for unrelated advertising or tracking.
5. Learning, AI and speech features
When you submit text, a transcript, a writing response or a PD3-style answer for correction, feedback, rewriting or assessment, LingoGap may send the submitted content and the educational context needed to perform the requested task to an external AI service.
LingoGap currently uses OpenAI API services for supported AI-assisted functionality.
OpenAI states that data submitted through its API is not used to train its models by default unless the customer affirmatively opts in.
OpenAI's own processing, security and retention practices are also governed by the applicable OpenAI terms and service configuration.
LingoGap does not require users to provide special-category or other highly sensitive personal information for ordinary language-learning features.
Please avoid including unnecessary sensitive or confidential information in free-text answers, transcripts, AI requests or support messages.
Speaking features require the user to activate the feature and may require microphone permission.
On Android, speech recognition may be provided by the device, operating system or an available speech-recognition service. Microphone audio may be processed by that service to produce transcript text.
LingoGap may process the resulting transcript for the learning feature you requested and may send transcript text and relevant learning context to the LingoGap backend and AI provider where necessary for feedback or assessment.
LingoGap does not intend to permanently store raw microphone recordings as part of ordinary learner records.
AI-assisted and automated educational results are practice features only.
They do not issue an official PD3 result or make decisions that produce legal or similarly significant effects concerning immigration, employment, educational admission or another comparable matter.
6. Native local data, import and backup
The LingoGap Native Android application may store learner data locally to provide continuity, offline or local application functionality and reliable operation.
Depending on the feature, local data may include learning progress, lesson state, flashcards and review information, PD3-style attempts, preferences and temporary application state.
Where offered, a user may choose to import supported learning data from an existing LingoGap Web or PWA account into the Native application.
The import copies supported data for the user's learning continuity and does not by itself delete the source account data.
Where the user uses LingoGap Backup and Restore, supported user-scoped learning data may be stored in LingoGap's cloud infrastructure under the authenticated account and later restored to the Native application.
Not every item stored on a device is necessarily transmitted to LingoGap servers.
Data is transmitted when required for synchronisation, backup, authentication, AI processing, subscription verification or another requested online feature.
Further information about browser, device and application storage is provided in the Cookie and Similar Technologies Policy.
7. Subscriptions and payments
Web subscriptions
Subscriptions purchased through the LingoGap website are processed using Stripe.
Stripe processes payment information and may provide LingoGap with the customer, subscription, billing and transaction information reasonably needed to grant access, administer the subscription, provide support, process refunds, handle disputes and meet accounting or legal obligations.
Payment-card credentials entered through Stripe's hosted payment environment are processed by Stripe.
LingoGap does not intend to receive or store complete payment-card numbers or card security codes.
Stripe may also process billing and subscription information such as invoices, receipts, subscription status, cancellation status and, where offered through Stripe's services, an optional cancellation reason provided by the user.
Depending on the processing activity, Stripe may process personal data on behalf of Uglecare ApS and may also act independently as a controller for purposes such as payment security, fraud prevention, regulatory compliance and related purposes.
Android subscriptions
Subscriptions purchased through LingoGap Native Android use Google Play Billing.
Google Play processes the purchase and payment.
LingoGap receives and processes subscription, product, entitlement and verification information reasonably necessary to associate the purchase with the correct LingoGap account, grant and maintain paid access, keep subscription status current, prevent fraud or account conflicts and provide subscription support.
Google may act as a separate controller for processing that it determines independently in connection with Google Play and other Google services.
Deleting a LingoGap account does not itself cancel an external Stripe or Google Play subscription.
Subscription cancellation must be completed through the applicable billing channel.
8. Service providers and recipients
Personal data may be processed by service providers and recipients where necessary to operate LingoGap.
Depending on the feature, these may include:
- Google and Firebase for authentication, cloud data and related services;
- Google Play for Android subscription billing and verification;
- Stripe for Web payments and subscription management;
- OpenAI for requested AI-assisted language and educational functionality;
- hosting and infrastructure providers such as Vercel and Cloudflare;
- speech-recognition or operating-system providers when a user activates a speaking feature;
- the support email provider used for customer and privacy communications; and
- authorised personnel, contractors, professional advisers or authorities where access or disclosure is necessary and legally permitted.
Service providers acting on behalf of Uglecare ApS are expected to process personal data only for the relevant authorised purpose and subject to applicable data-protection obligations.
Some providers may act as separate controllers for parts of their own processing.
9. International transfers
Some service providers may process personal data outside Denmark or outside the European Economic Area.
Where GDPR requires safeguards for a transfer outside the EU/EEA, an appropriate transfer mechanism must apply.
Depending on the provider and destination, this may include:
- an adequacy decision;
- the EU-US Data Privacy Framework where applicable;
- Standard Contractual Clauses; or
- another mechanism permitted by applicable data-protection law.
You may contact support@lingogap.dk for available information about applicable transfer safeguards.
10. Retention and account deletion
LingoGap retains personal data only for as long as reasonably necessary for the purpose for which it is processed and for applicable legal, accounting, security, fraud-prevention and dispute-resolution requirements.
In general:
- account and learning data may be retained while the account remains active and while needed to provide saved learning functionality;
- subscription, transaction, refund and accounting records may be retained for the period required or permitted by applicable law;
- support correspondence may be retained while needed to resolve the matter and for reasonable complaint, legal or continuity purposes;
- technical, security and operational records are retained according to their purpose, security needs and applicable provider processes; and
- local Native data remains on the device until removed by the application, account-deletion process, application-data clearing or uninstallation, as applicable.
Account deletion can be initiated directly within the LingoGap application and through the external account-deletion resource at:
https://www.lingogap.dk/account/delete
When a valid account-deletion request is completed, LingoGap deletes or anonymises eligible personal data associated with the account from systems controlled by LingoGap, subject to data that must or may lawfully be retained for purposes such as:
- accounting;
- tax;
- payment disputes;
- fraud prevention;
- security;
- legal obligations; or
- legal claims.
Where a service provider processes account data on behalf of LingoGap, appropriate deletion action will be taken where required and applicable.
Provider-controlled records, including Google Play or Stripe payment and transaction records retained for their own purposes, are governed by the applicable provider's legal obligations and privacy practices.
Account deletion and subscription cancellation are separate processes.
11. Security
LingoGap uses technical and organisational measures intended to protect personal data against unauthorised access, loss, misuse or disclosure.
These measures include appropriate authentication and access controls, user-scoped data access, encrypted network transmission, provider security controls and restrictions on authorised access.
No online service can guarantee absolute security.
Users should protect their account credentials and promptly report suspected unauthorised account access to:
12. Your data-protection rights
Subject to the conditions and exceptions in applicable law, you may have the right to:
- receive information about the processing of your personal data;
- request access to personal data held about you;
- request correction of inaccurate or incomplete information;
- request deletion of personal data;
- request restriction of processing;
- receive certain data in a portable format where the legal requirements for data portability are met;
- object to processing based on legitimate interests; and
- withdraw consent where processing is based on consent.
The right to deletion is not absolute.
Data may be retained where continued processing is required or permitted by applicable law.
To exercise a privacy right, contact:
Please provide enough information to identify your account and understand the request.
Reasonable identity verification may be requested where necessary to protect against unauthorised access or deletion.
Requests will be handled within the time required by applicable law.
You also have the right to lodge a complaint with the competent data-protection supervisory authority.
In Denmark, the supervisory authority is:
Datatilsynet
The Danish Data Protection Agency
Information about Datatilsynet is available at:
13. Children
LingoGap is intended primarily for adult Danish learners and is not specifically directed at children.
A person under 18 may not independently purchase a recurring paid subscription and should use LingoGap only with the permission and supervision of a parent or legal guardian.
Where processing of a minor's personal data requires consent, parental authorisation or another safeguard under applicable law, the required consent, authorisation or safeguard must be obtained.
14. Analytics, advertising and tracking
LingoGap does not currently use its Web or Native Android application for behavioural advertising, personalised advertising, session replay or cross-service advertising tracking.
The current reviewed implementation does not use third-party behavioural analytics for advertising or marketing purposes.
If LingoGap introduces optional analytics, marketing, advertising or other tracking that requires consent or additional disclosure, the relevant privacy information and consent mechanism will be provided before the technology is activated where required by law.
15. Changes and contact
This Privacy Policy may be updated when LingoGap's functionality, providers, processing activities, legal requirements or organisational arrangements change.
The current version and effective date will be displayed at the top of this Policy.
Where a change materially affects users' privacy rights or the way personal data is processed, appropriate notice will be provided where required by law.
For privacy questions, data-protection requests or security concerns, contact:
LingoGap
Data controller:
Uglecare ApS
CVR: 34353255
Borups Allé 116, st. tv.
2000 Frederiksberg
Denmark
Telephone: +45 91 41 20 66
Email: support@lingogap.dk
Website: https://www.lingogap.dk