Privacy policy — Amayagwa

1. Who we are

Amayagwa is run by [ASBL legal name] ASBL, a non-profit association under Belgian law, registered office at [registered office address] ("we", "us"). We are the controller of the personal data described in this policy.

For any question about your data, or to exercise your rights, write to amayagwa.asbl@gmail.com. We have not appointed a data protection officer, as the law does not require one for an organisation of our size and activity; the address above reaches the people responsible for data protection.

2. What data we process

We only collect what the service needs. Depending on how you use Amayagwa, this covers:

Account data: your name, email address and role (learner, parent, professor or administrator). If you sign in with Google, we receive your name and email from Google; we never see your Google password.
Child profiles: when a parent adds a child, the child's first name and age group (child or teen). A child has no login of their own; the parent's account manages the profile.
Learning data: onboarding answers (display name, age group, why you are learning), progress, scores, experience points, streaks, homework assigned by a professor, and notes shared with you.
Classes: the learner and professor, date and time, topic, the video-call link, the notes written before and after the class, including cancellation reasons, and the reminders we send you about them.
Recordings: a class is only recorded, and a contributor's voice only collected for pronunciation examples, with the consent of the person concerned, or of a parent for a child. We then keep the recording, the names of those involved, who consented and when, and, for pronunciation examples, the speaker's region.
Professor data: your application (name, email, country, languages, specialities, experience, motivation), your public profile (bio, languages, specialities, rating, classes taught) and your availability.
Professor absences: the reason for an absence and, where you choose to provide one, a supporting document. A medical note is health data; it is only seen by the administrators who manage the schedule.
Payment data: your plan, subscription status, billing period and the references Stripe gives us for your customer account, payments and invoices. Your card details go directly to Stripe; we never receive or store them.
Messages to us: feedback you send and reports you make about an exercise, with your name and role.
Technical data: your IP address, held in memory for a few minutes to limit abusive request rates, server logs needed to run and secure the service, and, when usage statistics are enabled, the address of the pages you visit.

Your name and email are needed to create an account; without them we cannot provide the service. Everything else is optional or created as you use Amayagwa.

3. Why we use it, and on what legal basis

To provide the service you signed up for: your account, lessons, progress, classes with professors, child profiles and your subscription. Basis: performance of our contract with you (art. 6(1)(b) GDPR).
To review professor applications and organise the professors' schedule. Basis: steps taken at your request before entering into an agreement, then performance of that agreement (art. 6(1)(b)).
To manage professor absences. Where a supporting document contains health data, we process it only to justify the absence and organise replacement classes, under art. 9(2)(b) and, where relevant, art. 9(2)(f) GDPR, with access restricted to administrators.
To take payments, keep accounting records and answer tax authorities. Basis: our contract with you and our legal obligations as a Belgian association (art. 6(1)(c)).
To keep the service secure, prevent fraud and abuse, and fix errors. Basis: our legitimate interest in running a safe service (art. 6(1)(f)).
To understand which lessons and features are used, through statistics that contain no name, email or account identifier. Basis: our legitimate interest in improving our teaching (art. 6(1)(f)).
To answer your messages and reports. Basis: our legitimate interest, or our contract with you when the message concerns your account.
To record classes and collect pronunciation examples. Basis: your consent, or a parent's for a child (art. 6(1)(a)), which can be withdrawn at any time.

We do not sell your data, we do not use it for advertising, and we make no decisions about you by automated means that have legal or similarly significant effects.

4. Children

Amayagwa teaches children as well as adults, so we treat their data with particular care. Under Belgian law, a child under 13 cannot consent alone to an online service. Children under 13 therefore only use Amayagwa through a child profile created and managed by a parent or legal guardian, who acts on the child's behalf and can see, change or delete the profile at any time.

We collect as little about children as we can: a first name, an age group and their learning progress. Usage statistics never include a child's name or any other identifying detail, and an automated check in our build process rejects any statistic that tries to.

5. Who we share it with

Your data is visible inside Amayagwa only to those who need it: your professor sees what is necessary to teach you, a parent sees their children's profiles, and our administrators see what they need to run the service. An administrator can view the app as a given account to resolve a problem; this requires an administrator's own sign-in and expires automatically after one hour.

We use the following service providers, who process data on our instructions under a data processing agreement:

Akamai Technologies (Linode): hosting of the application, database and file storage, in data centres in Paris, France.
Clerk, Inc.: account sign-in and session management. Clerk is based in the United States; transfers are covered by the European Commission's standard contractual clauses and, where Clerk is certified, the EU-US Data Privacy Framework.
Stripe Payments Europe, Ltd. (Ireland): payment processing. Stripe also acts as an independent controller for its own fraud-prevention and legal obligations, described in Stripe's privacy policy.
Google: if you choose to sign in with Google, or join a class through a Google Meet link, Google processes your data as an independent controller under its own privacy policy.
OpenAI: only the text of illustration prompts written by professors when they create lesson cards. No learner data is sent.

We may disclose data when the law requires it, for example to a court or a public authority acting within its powers.

6. Transfers outside the European Union

Our servers are in the European Union. Where a provider listed above processes data outside the European Economic Area, we rely on an adequacy decision of the European Commission or on its standard contractual clauses, with the additional measures they require. You can ask us for a copy of these safeguards at amayagwa.asbl@gmail.com.

7. How long we keep it

Account, child profiles and learning data: for as long as the account exists. When an account is deleted, we erase this data within 30 days, apart from what follows.
Class records and notes: for as long as the learner's and the professor's accounts exist.
Professor applications that are not accepted: 12 months after our decision, then erased.
Absence supporting documents: for as long as needed to manage the absence, and no more than 12 months.
Invoices and accounting records: 7 years, as required by Belgian accounting law.
Payment event records from Stripe: 12 months, for resolving payment disputes.
Feedback and reports: 24 months.
Recordings: until the date agreed when consent was given, and erased as soon as consent is withdrawn.
IP addresses used for rate limiting: a few minutes, in memory only. Server logs: a few days.

8. Your rights

You have the right to:

access the data we hold about you and receive a copy;
have inaccurate data corrected;
have your data erased, including by deleting your account;
restrict how we use it;
receive the data you gave us in a structured, machine-readable format (portability);
object at any time to processing based on our legitimate interest;
withdraw any consent you gave, without affecting what was done before.

To exercise a right, write to amayagwa.asbl@gmail.com from the address linked to your account. Parents exercise these rights for their children's profiles. We answer within one month; we may ask you to confirm your identity first.

If you think we have not respected your rights, you can lodge a complaint with the Belgian Data Protection Authority (Autorité de protection des données / Gegevensbeschermingsautoriteit), rue de la Presse 35, 1000 Brussels, www.dataprotectionauthority.be, or with the authority of the EU country where you live.

9. Cookies and storage on your device

We only use storage that the service needs to work, so we do not ask for cookie consent. We use no advertising or tracking cookies.

Sign-in cookies set by Clerk, which keep you signed in securely.
Cookies set by Stripe inside the payment form, to process payments and prevent fraud.
A temporary cookie used only when an administrator views the app as another account; it expires after one hour.
Local storage in your browser for your language, theme, onboarding answers, progress and kid-mode settings, so the app works quickly and offline. This stays on your device; you can clear it from your browser settings.

Our usage statistics run on a server we operate. They set no cookies and receive no name, email or account identifier; like any web request, they see your IP address, which we do not use to identify you.

10. Security

Data is encrypted in transit (HTTPS). Access to the database and files is limited to the people and systems that need it, and every protected page and endpoint checks the role of the person asking. No system is perfectly secure; if a breach puts your rights at risk, we will tell you and the supervisory authority as the law requires.

11. Changes to this policy

We update this policy when what we do with data changes. The date at the top shows the latest version. If a change is significant, we will tell you by email or in the app before it takes effect.