Privacy Policy

Last updated: June 5, 2026

1. Introduction

Devnorth ("we", "us", or "our") operates the Vintio mobile application ("the App"). This Privacy Policy explains how we collect, use, and protect your personal information when you use Vintio. By using the App, you agree to the practices described in this policy.

2. Age requirements and children's privacy

Vintio is not intended for users below the applicable minimum age in their region:

• Users in the European Union must be at least 16 years old.
• Users in the United States must be at least 13 years old in compliance with the Children's Online Privacy Protection Act (COPPA).
• Users in all other regions must meet the minimum age required by their local laws, which is typically 13 years old.

We do not knowingly collect personal information from users below the applicable minimum age. If you believe we have collected such information, please contact us immediately at soporte@dvnorth.com and we will delete it promptly.

3. Information we collect

We collect the following types of information:

• Account information: your name, email address, and country when you register.
• Language level: your self-reported English proficiency level (A1–C2).
• Voice data: audio input during AI conversations, sent in real time to Google Cloud (Vertex AI / Gemini Live API) to generate the AI's conversational responses. Audio is not stored permanently after the session ends.
• Conversation transcripts: text transcriptions of your practice sessions, generated by Google Cloud (Vertex AI / Gemini Live API) and used to produce performance reports within the app.
• Subscription data: purchase history and subscription status, managed through Apple In-App Purchase.
• Usage data: how you interact with the app, sessions completed, and performance scores.
• Device information: device type, operating system version, and app version.

4. How we use your information

We use your information to:

• Provide and personalize the Vintio experience based on your English level.
• Generate AI-powered conversation sessions by sending your voice and conversation data to Google Cloud (Vertex AI / Gemini Live API).
• Produce performance reports at the end of each session.
• Process subscription payments through Apple.
• Improve the quality and accuracy of our AI conversations.
• Communicate important updates about the service.

5. Third-party services

Vintio integrates with the following third-party services:

• AI voice processing (Google Cloud — Vertex AI / Gemini Live API): your voice input and conversation transcripts are sent to Google Cloud in real time to generate the AI conversational responses that power the app's core feature. This data is used solely to generate conversation responses and is not used by Google for advertising or any other purpose. Audio is not retained by Google after the session ends. Before any voice data is sent, the app requests your explicit consent.
• Cloud infrastructure: our backend is hosted on a third-party cloud platform with industry-standard security.
• Apple In-App Purchase: handles all subscription payments. Apple's privacy policy governs payment processing.

We do not sell your personal data to any third party.

6. Legal basis for processing (GDPR)

If you are located in the European Union, we process your personal data under the following legal bases:

• Contract performance: to provide the services you signed up for.
• Legitimate interests: to improve the app and ensure security.
• Consent: for any optional data collection such as analytics.

7. Data retention

We retain your account information for as long as your account is active. Conversation audio is processed in real time and not stored after the session ends. Transcripts and performance scores are retained to provide your learning history within the app. You may request deletion of all your data at any time.

8. Your rights

Depending on your location, you may have the following rights:

• Access the personal data we hold about you.
• Request correction of inaccurate data.
• Request deletion of your account and all associated data — available directly from the app under Account → Delete Account.
• Request restriction of processing or object to processing.
• Request data portability (EU users).
• Withdraw consent at any time without affecting the lawfulness of prior processing.
• Lodge a complaint with your local data protection authority (EU users).

9. Data security

We implement industry-standard security measures including encrypted data transmission (HTTPS/TLS), token-based authentication, and role-based access controls. However, no method of transmission over the internet is 100% secure and we cannot guarantee absolute security.

10. International data transfers

Your data may be processed on servers located outside your country of residence. When transferring data internationally, we ensure appropriate safeguards are in place in accordance with applicable law.

11. Changes to this policy

We may update this Privacy Policy from time to time. We will notify you of significant changes through the App. Continued use of Vintio after changes constitutes your acceptance of the updated policy.

12. Contact

If you have any questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us at soporte@dvnorth.com.