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Privacy Policy

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Last updated: 5 September 2026

Data Controller

Controller: Nomino, operated by the developer identified on Nomino's App Store listing
Privacy contact: support@nomino.pro

Introduction

Nomino is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application and related services.

Information We Collect

Information You Provide

  • Account Information: Email address, name, and profile information
  • Learning Data: Language preferences, learning progress, conversation history
  • User Content: Voice streams and transcripts used during AI practice, plus conversation summaries and memory facts saved to personalize later sessions

Information Collected Automatically

  • Usage Data: Features used, session duration, learning patterns
  • Device Information: Device type, operating system, unique device identifiers

How We Use Your Information

We use the information we collect to:

  • Provide and improve our language learning services
  • Personalize your learning experience
  • Process AI-powered conversations and feedback
  • Send you important updates and notifications
  • Measure account-level usage to enforce service limits and subscription access
  • Process subscription payments through RevenueCat
  • Comply with legal obligations

Lawful Bases for Processing

We process your data under the following lawful bases:

  • App functionality (account, lessons, conversations): Art. 6(1)(b) – contract performance
  • Payments & subscriptions (via RevenueCat/Apple): Art. 6(1)(b) – contract; Art. 6(1)(c) – legal obligations (tax/records)
  • Security, reliability and abuse prevention: Art. 6(1)(f) – legitimate interests
  • AI processing and voice synthesis (Google Gemini) and real-time voice (LiveKit): Art. 6(1)(b) – contract performance

Third-Party Services & Sub-Processors

We use vetted providers to run Nomino. The current list (purposes, regions, data types, retention) is maintained at nomino.pro/subprocessors. Last updated: 5 September 2026.

Key sub-processors include:

  • Google Cloud, Firebase and Gemini: authentication, database, storage, server functions, AI content generation, transcription and voice synthesis
  • LiveKit: real-time voice communication
  • RevenueCat: subscription entitlement management

International Data Transfers

Primary Hosting Regions: Core application data is hosted in the EU region (europe-west) on Firebase/Firestore. Some processors may operate in the US.

When we transfer data outside the UK/EEA (e.g., to the US), we use the UK Addendum to the EU SCCs or the UK IDTA, plus supplementary measures where needed. Copies of the relevant transfer mechanism can be requested at support@nomino.pro.

Security

We use technical and organisational measures to protect your data, including:

  • Encryption in transit: All data transmitted between your device and our servers uses HTTPS/TLS
  • Encryption at rest: Sensitive data is stored encrypted in Firebase Firestore
  • Access controls: authenticated, user-scoped access to private profile data
  • Breach notification: If we become aware of a data breach that risks your rights and freedoms, we will notify you and regulators in line with legal requirements

Note: We do not use end-to-end device-level encryption. Conversations are encrypted in transit and at rest on our servers.

Data Retention

We retain your data for the following periods:

  • Account, profile and learning progress: retained while your account is active and deleted when in-app account deletion completes, subject to any retention required by law
  • Conversation summaries and memory facts: retained for cross-session personalization until you delete memories or your account
  • Voice audio: transmitted for real-time processing; Nomino does not retain raw voice recordings after the live session
  • Subscription records: retained by Apple and RevenueCat under their applicable legal and service requirements; Nomino deletes its RevenueCat customer record during account deletion

Automated Decision-Making & Profiling

We personalise lessons, assess pronunciation (e.g., scoring 0–100), and recommend content automatically. These processes affect lesson ordering and feedback only and do not produce legal or similarly significant effects. You may object to profiling or request a manual review by emailing support@nomino.pro.

Your Rights

You have the right to:

  • Access your personal data
  • Correct inaccurate data
  • Request deletion of your data
  • Export your data
  • Object to certain processing (including profiling)
  • Opt-out of marketing communications
  • Withdraw consent at any time

Response time: We respond to data subject requests within one month (we may extend by up to two months for complex requests).

Children's Privacy

Nomino is not directed to users under 13 and does not knowingly collect their data. We design our service with the UK Age-Appropriate Design Code in mind and do not use behavioural advertising or sell personal data. If we learn that a user is under 13, we will disable the account and delete associated personal data after reasonable verification. If you believe we have collected information from a child under 13, please contact us immediately at support@nomino.pro.

Marketing

Transactional vs Marketing: We send transactional emails (e.g., receipts, service notices) as part of our contract with you and they do not require consent. Marketing emails (tips, offers) are sent only with your consent. You can unsubscribe via any marketing email or in-app at Profile → Settings → Notifications.

Complaints

You can complain to the UK Information Commissioner's Office (ICO): ico.org.uk. We'd appreciate the chance to resolve concerns first at support@nomino.pro.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last updated" date.

Contact Us

If you have questions about this Privacy Policy or our data practices, please contact us at support@nomino.pro or visit our Support Page.

Document History

  • 5 September 2026: Updated service providers, retention, memory processing and security details
  • 9 November 2025: Initial publication