Private by design, explained clearly.

1. Who is responsible

Email: contact@gotolcs.com

goto LCS UG is responsible for the Lingo Luna app, this website, and support correspondence as described below.

2. Information stored by the app

Lingo Luna saves learning information inside the app’s local container first. When iCloud is available and permitted in device Settings, the app also syncs learner information automatically to that Apple Account’s private CloudKit database. This can include:

• A learner nickname or name entered locally, a randomly generated profile identifier, and the selected avatar.
• Language choices, lesson progress, Starlight (lesson points), stars, streaks, practice history, completion dates, mistake records, per-item mastery history, puzzle pieces, trophy facets, and puzzle completion.
• Daily active learning time, completed-round counts, parent-selected time and round limits, and extra allowance granted for a day.
• Sound, haptic, motion, and other comfort settings.
• Sync metadata, including random installation identifiers, change timestamps, counters, and deletion markers, used to merge progress without duplicate counts.

The app stores Apple’s app-scoped CloudKit account identifier locally to keep accounts separate. These identifiers are not used for advertising or tracking. If a progress file cannot be read, a recovery copy may be kept locally; that recovery file is not part of the app’s CloudKit sync payload.

The app uses this information to provide and restore learning, show parents each learner’s progress and activity, and enforce optional daily limits on that device. Synced daily activity is combined, but disconnected devices cannot enforce one live shared time allowance. Time in Parents or the background does not count. Lingo Luna does not transmit this information to goto LCS UG or a developer-operated service.

Home Screen widgets read a local snapshot of learner names, language choices, progress, and display content from an App Group container shared only with Lingo Luna’s own widget extension. The extension does not access the microphone or sync directly with CloudKit. The app uses device language, operating-system capabilities, network availability, and timing information to choose its interface, support compatible features, retry sync, and measure learning time.

When parental controls are configured, parent access stores a salted PIN verifier and failed-attempt or lockout information separately in the device’s Keychain. Lingo Luna does not store the PIN as plain text or sync this record to the cloud. Forgotten-PIN recovery uses Apple’s device-owner authentication; the app receives its result, not the device passcode or biometric data.

3. Purchases and payments

Lingo Luna is free to download. An optional, one-time Full Access purchase unlocks the remaining themes in every course. There is no subscription.

Purchases go through Apple. Apple processes the payment, restoration, refunds and Family Sharing through your Apple Account, under Apple’s own terms and privacy policy. No payment information, such as card details, billing address or Apple Account details, reaches goto LCS UG. Apple provides goto LCS UG only with aggregated sales reports that do not identify you or a learner.

To unlock content, the app checks Apple’s signed purchase information on the device. The same check recognizes customers who bought the original paid version of the app. Purchase information is not sent to goto LCS UG or a developer-operated server, and it is linked to the Apple Account rather than to a learner profile. Purchase and restore controls are inside the parent-protected Parents area.

4. Microphone and speech recognition

Microphone and Speech Recognition access is requested only when a learner chooses to use a microphone control in an optional speaking activity.

Lingo Luna requires Apple’s on-device speech recognition. Audio and the resulting transcript are used during the activity to compare an answer with the authored lesson phrase. A temporary audio file supports the active recognition session and is removed when the speech service resets or the activity closes. If the app is interrupted abruptly, the operating system may retain that temporary file until it performs its normal cleanup.

goto LCS UG does not receive the recording or transcript. Speaking can be skipped, and permissions can be withdrawn in iOS or iPadOS Settings.

5. Bundled AI-generated offline voice

On iOS or iPadOS 18 and later, Lingo Luna includes and automatically uses a multilingual voice model for English, Spanish, and German as part of the installed app, with no separate model download. A compatible Apple system voice is used automatically on earlier supported operating-system versions or whenever Lingo Luna Voice is unavailable.

Lingo Luna Voice uses FluidAudio and the Supertonic 3 Core ML model. The model and software source and license information is available from the FluidInference model repository and in the app’s license notices.

English, Spanish, and German speech is AI-generated on the device. Lesson text, answers, transcripts, and generated audio do not leave the device for voice synthesis. The app identifies the voice as AI-generated and makes the model and software license notices available inside Parents → Settings.

6. What the app does not include

Lingo Luna has no developer-operated account system, advertising, analytics, crash-reporting, tracking, social network or content API. Progress sync uses Apple’s private CloudKit storage; there is no developer-operated learner-data server. The curriculum and Lingo Luna Voice model are bundled with the app; the app does not fetch model files or generate learner speech through a remote voice service.

Apple may separately process App Store downloads, in-app purchases, aggregate product metrics, diagnostics shared with Apple, private iCloud storage and iCloud backups under Apple’s own terms and privacy policies.

7. Visiting this website

When this website is opened, hosting and security providers process technical request data needed to deliver and protect it. This can include the IP address, time of access, requested page, referring page, browser or device information, and routing or security data.

The legal basis is our legitimate interest in reliably and securely providing the website (Article 6(1)(f) GDPR). The site does not use advertising trackers or optional analytics cookies. Our website is hosted through Amazon Web Services (AWS), which may process technical request data as a service provider. AWS explains its data practices in its Privacy Notice and Data Privacy FAQ.

Technical data is retained only for as long as required to deliver, secure, diagnose, and operate the service, according to the applicable hosting and security settings.

8. Contacting support

If you email contact@gotolcs.com, we receive your email address, message, and any information you choose to include. Support email is handled through Google Workspace.

We use this information to respond to and document the request. The legal basis is Article 6(1)(b) GDPR when the request concerns an app-related contract or pre-contractual question, and otherwise our legitimate interest in providing support under Article 6(1)(f) GDPR.

Correspondence is kept only as long as necessary to resolve and document the request or comply with legal obligations. Please do not send voice recordings, full legal names of other people, or sensitive information that is not needed for support.

9. International processing

Some providers used for website infrastructure and support email may process information outside the European Economic Area. Where required, transfers are protected through an adequacy decision, the EU Standard Contractual Clauses, or another lawful safeguard.

10. Retention and deletion

Learning information remains in the local app container until it is changed through use or the app is deleted. Deleting the app removes that container from the device, but it does not delete the private iCloud copy or an existing Apple device backup. Deleting a learner or resetting learning in Parents propagates to other devices after sync. Resets preserve parent limits and daily usage; deleting a learner removes the learner’s profile and ledger. Manage the separate cloud copy in Apple’s iCloud storage settings. If the app detects that a previously synced cloud copy was removed, automatic upload pauses; recreating it requires Upload saved progress in Parents → iCloud. The bundled voice model is part of the installed app rather than learner data. Deleting or offloading the app removes that bundled model; offloading preserves local Documents & Data such as profiles and progress for a later reinstall.

Parent-access data is held separately in the device’s Keychain. If a PIN is still requested after reinstalling the app, use device-owner authentication in Parents to replace it.

Because goto LCS UG does not receive or store learner profiles, progress, or daily activity counts, there is no developer-held learner record to retrieve or delete. Website and support information follows the retention practices described above.

11. Your rights

Where the GDPR applies, you may have rights to access, correct, erase, restrict, or receive personal data, and to object to certain processing. You may also lodge a complaint with a data-protection authority.

Our competent supervisory authority is the Bayerisches Landesamt für Datenschutzaufsicht (BayLDA). You can learn more at lda.bayern.de.

To exercise a right or ask a privacy question, email contact@gotolcs.com.

12. Children and parent guidance

Lingo Luna is designed for young learners with parent guidance. Its interface and lesson instructions follow the course’s teaching language: English, Spanish or German. Families can start immediately; parents can optionally set a local PIN and daily limits and choose learner nicknames and courses. Learner settings and external links are inside the protected Parents area.

The app does not ask for an age, email address, online account, precise location, photo, contacts, or payment information; Apple handles the optional purchase. Parents should choose appropriate local nicknames, guide learning, and manage device permissions, iCloud access and backups. Keep the parent PIN and device-owner authentication under a parent’s control.

13. Changes to this policy

We may update this policy when the app, website, or applicable requirements change. The effective date at the top will identify the current version. Material changes affecting the app will be reflected here before the relevant update is released.