Privacy Policy
In plain English: what we collect, what we never see, and what you can do about it.
Last updated: 9 June 2026
This is a plain-English summary of how Pinguingo handles your data, written to be read rather than skimmed past. It is not a substitute for legal advice. If you operate Pinguingo, have a lawyer review this before you rely on it.
Pinguingo is a service run by [Registered owner name], a sole proprietorship (eenmanszaak) based in the Netherlands, registered with the Dutch Chamber of Commerce (KvK) under number [KvK number]. In this policy, “we” and “us” mean that business, and “you” means the person using Pinguingo. Because we are based in the Netherlands, we handle your personal data under the EU General Data Protection Regulation (GDPR).
What we collect
- Account details. Your email address and, if you sign up, your name and the language you are learning.
- Your WhatsApp number. So we can drip flashcards and prompts to you on WhatsApp.
- Messages you send to Pinguingo. The replies you send to our WhatsApp number, so we can tell what stuck and what to resurface.
- Learning data. Your word lists, progress, review history, and the settings that shape your daily practice.
- Payment metadata. When you subscribe, our payment processor handles your card details. We receive only what we need to run your subscription, such as your plan, billing status, and the last few digits of your card. We never see or store your full card number.
- Basic technical data. Things like your browser type and approximate region, collected to keep the service secure and working.
What we never see
Pinguingo is a contact you message, like any business on WhatsApp. We only see the replies you send to the Pinguingo number directly. We never see your group chats, your direct messages with other people, or anything you do not send to us. WhatsApp messages are end-to-end encrypted between you and us by WhatsApp itself.
Why we use your data
- To send you flashcards, prompts, and audio on WhatsApp.
- To personalise your practice: deciding what to show next and what to bring back.
- To run your account, subscription, and support requests.
- To keep the service secure and to fix problems.
- If you work with a tutor, to let your tutor steer the vocabulary you receive and see your progress on the lists they assign.
Under the GDPR, our legal grounds for this are performing our contract with you (running the service you signed up for), our legitimate interest in keeping Pinguingo secure and improving it, and your consent where the law requires it.
Who we share it with
We do not sell your data. We share it only with the services we need to run Pinguingo, and only as much as each one needs:
- WhatsApp / Meta, to deliver messages to your number.
- Stripe, our payment processor, to handle subscriptions and card payments securely.
- Our hosting and infrastructure providers [Data hosting provider], who store the data that runs the service.
- Your tutor, if you are learning with one, limited to the lists and progress that relate to your lessons.
Some of these providers may process data outside the European Economic Area. Where they do, they are bound by safeguards such as the EU Standard Contractual Clauses.
How long we keep it
We keep your data for as long as you have an account, plus a short period afterwards so you can come back where you left off. When you ask us to delete your account, we remove your personal data, except anything we are legally required to keep, such as invoices for tax purposes.
Your rights
Under the GDPR you can ask us to show you the data we hold, correct it, export it, or delete it, and you can object to or restrict how we use it. To exercise any of these, email us at info@pinguingo.com. If you think we have mishandled your data, you also have the right to complain to the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).
Contact
Questions about your privacy or this policy? Email info@pinguingo.com and a human will get back to you.