1. Data Controller

The data controller responsible for your personal data is Craftlures Khomyak, Org.nr: 932 341 093, Fjellvegen 2, 6770 Nordfjordeid, Norway.

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2. What data we collect

When you use INFLINGO, we may collect:

• Your Telegram ID and username
• Voice messages (processed for speech recognition; not stored permanently — see Section 8 for retention details)
• Text messages within learning sessions
• Progress, level, and preference data
• Email and payment-related information when you subscribe (via Stripe or Paddle)
• Technical data: IP address, device type, session timestamps

3. How we use your data

We use your data to:

• Provide and operate the INFLINGO service
• Personalize your learning experience
• Process payments and manage your subscription
• Provide technical support and improve the service
• Send required notices about your active subscription (as required under Norwegian law)

4. Legal basis for processing (GDPR)

We process your data based on the following legal grounds:

- Contract performance — to deliver the service you subscribed to

- Consent — for marketing communications

- Legitimate interest — for security and service improvement

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5. Third-party services and international data transfers

We work with the following third-party services:

• Anthropic (Claude API) — processing of language requests
• ElevenLabs — generation of audio content
• OpenAI (Whisper) — speech recognition
• Stripe and/or Paddle — payment processing and subscription management. Where Paddle is used, Paddle also collects and processes limited data (such as your country and, where applicable, VAT/tax ID) as required to calculate and remit applicable sales tax or VAT, acting as Merchant of Record for that transaction.
• Telegram — communication platform

Some of these providers (including Anthropic, ElevenLabs, and OpenAI) are located outside the European Economic Area (EEA), including in the United States. Where this is the case, we ensure an appropriate legal basis for the transfer, such as Standard Contractual Clauses approved by the European Commission or the provider's certification under the EU-U.S. Data Privacy Framework, where applicable.

We do not sell your personal data to third parties.

6. Cookies

inflingo.no uses technical cookies necessary for the website to function. Analytics cookies are used only with your consent.

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7. Data retention

We retain your personal data only for as long as necessary for the purposes described in this policy:

• Voice messages are processed for speech recognition and deleted shortly after processing; they are not stored on a long-term basis.
• Account, progress, and subscription data are retained for as long as your account remains active, and for a limited period afterward as required for legal, tax, or accounting purposes.
• You may request earlier deletion of your data at any time, subject to Section 9 below.

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8. Data security

Your data is securely stored on servers located in Norway/the EEA. Payment data is stored exclusively on the servers of our payment providers (Stripe and/or Paddle) and is not directly accessible to us.

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9. Your rights

Under GDPR and Norwegian data protection law, you have the right to:

• Access your personal data
• Correct inaccurate data
• Request deletion of your data ("right to be forgotten")
• Restrict processing
• Data portability
• Withdraw consent at any time

To exercise these rights, contact us at: info@inflingo.no

10. Children's privacy

Our services are subject to the age requirements set out in our Terms and Conditions. We do not knowingly collect personal data from children below the applicable minimum age without appropriate parental or guardian consent. If you believe a child has provided us with personal data without such consent, please contact us so we can take appropriate action.

11. Changes to this policy

Material changes will be communicated via Telegram or email at least 30 days before they take effect.

12. Contact

If you have questions about privacy, contact us at: info@inflingo.no

Craftlures Khomyak · Org.nr: 932 341 093 · Fjellvegen 2, 6770 Nordfjordeid, Norway

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