Privacy Policy

Last updated: October 13, 2026

1. Data Controller Identification & Introduction

This Privacy Policy explains how personal data is collected, processed, and safeguarded by the official Data Controller:

PRANA SMART, LDA ("LinQo," "we," "our," or "us") is dedicated to protecting your fundamental right to privacy in full compliance with Regulation (EU) 2016/679 (General Data Protection Regulation — "GDPR"), the Portuguese Data Protection Act (Lei n.º 58/2019), the California Consumer Privacy Act as amended by the California Privacy Rights Act ("CCPA/CPRA"), Directive 2002/58/EC ("ePrivacy Directive"), Apple App Store Review Guidelines (Guidelines 4.4, 5.1.1, and 5.1.2), and Google Play Developer Program Policies (2026 Edition: User Data Policy, Data Safety Mandate, Account Deletion, and Zero-Keylogger Input Method Policies).

2. Information We Collect: Apple Nutrition Labels & Google Play Data Safety Mapping

In accordance with Apple App Store Privacy Nutrition Labels, Apple Privacy Manifests (PrivacyInfo.xcprivacy), and the Google Play Data Safety declaration, we collect only the minimal data necessary to deliver our multi-platform translation services:

Tracking & Advertising Declaration: LinQo does NOT track you across applications or websites owned by third parties (NSPrivacyTracking = false). We do NOT collect or utilize Apple's Advertising Identifier (IDFA) or Google Advertising ID (GAID) for advertising, and we never share your data with advertising networks, brokers, or data aggregators.

3. Purpose of Processing and Lawful Legal Bases (GDPR Article 6)

We process personal data strictly where permitted by Article 6 of the General Data Protection Regulation (GDPR):

• Execution of Requested Translations & Tone Styling: Processed pursuant to GDPR Article 6(1)(b) (Performance of a Contract). Transmission of your composed sentence is strictly necessary to perform the real-time translation requested by you.
• Voice Recognition & Audio Processing (Web & Bot Only): Processed pursuant to GDPR Article 6(1)(a) (Explicit Consent) and Article 6(1)(b). Audio is streamed ephemerally and discarded immediately. We do NOT store or create biometric voiceprints or templates under GDPR Article 9.
• Infrastructure Security, Abuse Defense & Rate Limiting: Processed pursuant to GDPR Article 6(1)(f) (Legitimate Interests). We maintain rolling security logs (IP addresses, request timestamps) for up to 30 days solely to protect our servers against DDoS attacks, automated scraping, and unauthorized API abuse.
• Billing, Tax & Regulatory Compliance: Processed pursuant to GDPR Article 6(1)(c) (Legal Obligation) to comply with European VAT directives and statutory Portuguese commercial and accounting standards.

4. Mobile Keyboards (iOS Custom Keyboard & Android IME) & Zero-Keylogger Architecture

LinQo strictly adheres to Apple's App Store Review Guideline 4.4 and Google Play's User Data & Input Method Editor (IME) Policies. LinQo is NOT a keylogger on any operating system. We DO NOT log, record, buffer, or transmit your raw keystrokes, passwords, credit card numbers, or private communications.

• Operating System Permissions & Disclosures:
  • iOS ("Full Access"): Apple requires all custom keyboard extensions that communicate over the internet to request "Allow Full Access." LinQo connects to our secure neural translation cloud solely to translate text in real-time upon your explicit request. Without network access, cloud AI translation cannot function.
  • Android System Warning ("Attention" Dialog) & Companion Voice Input (RECORD_AUDIO): When enabling any third-party keyboard on Android, the operating system displays a standard security prompt ("This input method may be able to collect all the text you type..."). The LinQo keyboard service (:ime) requests only standard android.permission.INTERNET to communicate with our translation API and requests zero microphone, camera, contacts, location, or storage permissions. The Android Companion Quick Sheet (LinQoQuickActivity in :app) optionally requests runtime android.permission.RECORD_AUDIO solely when you tap the microphone icon to dictate text via Android's native SpeechRecognizer service; raw audio is processed ephemerally by the OS speech recognition engine and is never transmitted to or stored on LinQo servers.
• Strict User-Initiated Transmission Triggers: All typing, character layout, autocorrection, and swipe gesture recognition take place 100% locally on your device. Text leaves your device ONLY upon explicit, intentional user action:
  1. Tapping the dedicated "Translate" button (transmits only the final composed text in the input field).
  2. Selecting "Rephrase" (transmits selected text to adjust tone or grammar).
  3. Selecting "Smart Replies" (transmits conversation context to generate reply suggestions).
  Background typing, unsubmitted text, and regular typing sessions are NEVER monitored, transmitted, or logged.
• Sensitive Field Protection & Complete Password Blackout:
  • iOS: The keyboard automatically detects secure text fields (such as password, PIN, or OTP entry fields via isSecureTextEntry) and completely disables all network transmission and autocompletion features.
  • Android: The keyboard automatically detects password fields via isInputPassword() covering TYPE_TEXT_VARIATION_PASSWORD, TYPE_TEXT_VARIATION_WEB_PASSWORD, TYPE_TEXT_VARIATION_VISIBLE_PASSWORD, and TYPE_NUMBER_VARIATION_PASSWORD. Active word buffers are immediately cleared, predictive suggestions are aborted, and local UserDictionary learning is strictly disabled.
  • Private Browsing: Respects the system private browsing flag (EditorInfo.IME_FLAG_NO_PERSONALIZED_LEARNING).
• Client-Side Data Loss Prevention (DLP): Before transmitting any text to our translation API, LinQo's built-in on-device DLP engine scans the payload using the Luhn algorithm to detect and automatically redact credit card numbers, API keys, and JWT authentication tokens.
• Offline Fallback: If network access is disabled or unavailable, LinQo continues to function seamlessly as an offline typing keyboard. Only network-dependent cloud features are disabled.
• Secure Local Storage & Sandboxing:
  • iOS: User preferences and authentication tokens are stored securely in the local iOS App Group container (group.com.bychkov.linqo.keyboard), protected by iOS hardware-level sandbox encryption and Keychain.
  • Android: User preferences and tokens are stored in private internal sandboxed storage using encrypted multi-process MMKV (v2.0.2) backed by hardware-level Android KeyStore (AES-GCM). Inter-process communication between the keyboard (:ime) and main application (:app) is strictly secured via signature-level permission com.linqo.permission.IPC.

5. Ephemeral Voice & Text Processing

All translation and voice inputs handled by LinQo are processed ephemerally in volatile memory:

• Voice Processing (Web & Telegram Platforms Only): Audio recorded via your microphone on our web application or Telegram bot is streamed directly to specialized speech-to-text providers (e.g., Deepgram) and text-to-speech providers (e.g., ElevenLabs) and is immediately destroyed post-conversion. Note: The LinQo iOS Custom Keyboard does not capture microphone audio; voice input on iOS utilizes Apple's native on-device dictation engine.
• Text Translation: Text sent for translation is processed in-memory and immediately returned to your active app. We do not maintain server-side logs, archives, or transcripts of your translated messages.

6. Third-Party AI Sub-Processors & International Data Transfers (GDPR Chapter V)

To provide high-precision neural translation, tone adaptation, and speech processing, LinQo engages vetted third-party AI infrastructure providers:

• OpenAI, LLC (USA): Powers contextual translation, tone adaptation, and AI draft generation. Certified under the EU-U.S. Data Privacy Framework (DPF) and bound by European Commission Standard Contractual Clauses (SCCs). Zero-data-retention API terms apply.
• DeepL SE (Germany): High-precision neural machine translation. All processing remains within the European Union / EEA.
• Deepgram, Inc. (USA): Ephemeral speech-to-text recognition (Web/Telegram only). Bound by SCCs and zero-retention policies.
• ElevenLabs, Inc. (USA): Ephemeral text-to-speech voice generation. Bound by SCCs.
• Amazon Web Services, Inc. (AWS) & Cloudflare, Inc. (USA/EU): Cloud hosting, API routing, and DDoS mitigation. Certified under DPF and bound by SCCs.

International Transfer Safeguards: Where personal data is transferred outside the EEA to the United States, transfers rely on the EU-U.S. Data Privacy Framework (DPF) adequacy decision pursuant to Article 45 GDPR, or on the European Commission Standard Contractual Clauses (SCCs) (Commission Implementing Decision (EU) 2021/914, Module 2) pursuant to Article 46(2)(c) GDPR, supplemented by TLS 1.3 encryption and zero retention at rest. You may request a copy of our transfer safeguards by emailing privacy@linqo.pro.

7. Data Security & Retention Schedules

We employ rigorous technical and organizational measures (TOMs) to safeguard your data:

• All network communications are secured using TLS 1.3 / HTTPS and Secure WebSockets.
• Authentication relies on signed, encrypted JSON Web Tokens (JWT) with automated expiration.
• Zero message content storage: translation payloads are held in volatile RAM only for the duration of the API call (milliseconds) and purged immediately upon response.
• Server infrastructure access logs (IP address, user-agent, timestamp) are rotated and permanently deleted every 30 days.

8. In-App and Web Account Deletion (Google Play & Apple Guideline 5.1.1(v) Compliance)

You maintain full autonomy over your account and personal data. You can permanently delete your account and all associated records directly from within the iOS and Android applications, or through our public web portal:

• Scope of Deletion: Initiating deletion immediately and irreversibly purges your account record, email address, registered device IDs, usage tallies, and authentication tokens from our production databases, and wipes local Keychain / MMKV tokens on your device.
• Manual Deletion Assistance: You may also request account and data deletion by emailing our Data Protection Officer at privacy@linqo.pro with the subject line "Account Deletion Request". Requests are fulfilled within 24–48 hours.

9. Your Data Subject Rights (GDPR Articles 15–22 & Article 77)

Under Chapter III of the GDPR, European Union residents possess the following enforceable statutory rights:

• Right of Access (Art. 15): Obtain confirmation of whether your data is processed and receive an export of your personal data.
• Right to Rectification (Art. 16): Correct inaccurate or incomplete personal records.
• Right to Erasure ("Right to be Forgotten") (Art. 17): Permanently delete your personal data from our systems.
• Right to Restriction of Processing (Art. 18): Request temporary freezing of data processing during disputes.
• Right to Data Portability (Art. 20): Receive your personal data in a structured, commonly used, machine-readable format (JSON/CSV).
• Right to Object (Art. 21): Object at any time to processing grounded on our legitimate interests under Art. 6(1)(f).
• Right to Withdraw Consent (Art. 7(3)): Revoke consent at any time without affecting the lawfulness of prior processing.
• Automated Decision-Making & Profiling (Art. 22): LinQo does not employ automated profiling or decision-making algorithms that produce legal effects concerning you.

Exercising Your Rights & SLA: You may exercise any of these rights free of charge by contacting privacy@linqo.pro. Pursuant to Article 12(3) GDPR, we will respond and fulfill your verified request within one calendar month (30 days).

10. California Privacy Rights (CCPA / CPRA Notice)

This section applies exclusively to California residents pursuant to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 ("CCPA/CPRA").

10.1 Categories of Personal Information Collected (Past 12 Months)

• Category A — Identifiers: Email address, unique device identifiers (IDFV), IP address (stored in rolling security logs for 30 days).
• Category B — Customer Records: User account profile details and active subscription status.
• Category D — Commercial Information: Purchase history, subscription tier, and daily translation count totals.
• Category F — Internet or Network Activity: App version, operating system, and request timestamp metadata.
• Category H — Audio / Electronic Information: Ephemeral microphone audio recordings (Web/Telegram only) processed strictly for real-time speech-to-text and discarded immediately.

10.2 California Consumer Rights

• Right to Know & Access: The right to request disclosure of the specific pieces and categories of personal information collected.
• Right to Delete: The right to request deletion of personal information collected from you.
• Right to Correct: The right to correct inaccurate personal data maintained about you.
• Right to Non-Discrimination: We will not discriminate against you (by denying services, charging different prices, or providing different quality) for exercising your CCPA/CPRA rights (Cal. Civ. Code § 1798.125).
• California "Shine the Light" Law (Civil Code § 1798.83): We do not disclose personal information to third parties for their own direct marketing purposes.

To exercise your California privacy rights, submit a verifiable consumer request to privacy@linqo.pro with the subject line "CCPA Consumer Request". We will confirm receipt within 10 business days and respond substantively within 45 days.

11. Children's Privacy

LinQo is not directed at children under the age of 13 (or under 16 in the European Union). We do not knowingly collect personal information from children. If you become aware that a child has provided us with personal information without parental consent, please contact us at privacy@linqo.pro, and we will take immediate steps to delete such information.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect technological, legal, or operational developments. In the event of material changes, we will notify you by updating the "Last updated" date at the top of this policy and providing prominent notice within the LinQo application or via email.

13. Contact Us

For any questions, requests, or concerns regarding this Privacy Policy or our data practices, please contact our Data Protection Officer:

• Data Controller: PRANA SMART, LDA (LinQo)
• Email: privacy@linqo.pro
• Legal Counsel: legal@linqo.pro
• Address: Porto Salvo, Oeiras, Portugal
• Website: https://linqo.pro