Privacy policy
Last updated: 20 October 2026
1. About this policy
This policy explains how Fun Learning Spanish collects and uses personal information when you:
- visit or buy from our shop at funlearningspanish.com (the "Shop");
- use our learning app at app.funlearningspanish.com (the "App"), including our AI helper Pico;
- sign up for our emails or free downloads, or contact us;
- book lessons with us.
There's a short version for younger learners in section 13.
2. Who we are and how to contact us
The "controller" responsible for your personal information is Sam Allison, trading as Fun Learning Spanish.
- Postal address: Lytchett House, 13 Freeland Park, Wareham Road, Poole, Dorset, BH16 6FA, United Kingdom
- Email: info@funlearningspanish.com
We're a small business, so we haven't appointed a Data Protection Officer (we're not required to). The owner handles all privacy questions personally.
3. What information we collect
When you buy from the Shop
- Contact and order details: name, email, billing and delivery address, phone number (if you give it), items bought and order history.
- Payment details: handled by Shopify Payments and the other payment providers shown at checkout. We only see limited details (for example card type and last 4 digits). We never see or store your full card number.
- Download records: when a digital file was downloaded, so we can deliver files, prevent misuse and handle refunds.
- Checkout consents: a record that you asked for immediate access to downloads and acknowledged losing your right to cancel.
When you use the App
- Sign-in details: your email address. You need it to sign in, usually with a one-time code we email to you. We never see or store a password.
- Date of birth: so we can apply our age rules, check for a parent's or guardian's permission where needed, and keep 18+ content away from under-18s.
- Parent or guardian permission: for users under 18, a record (with date and time) that you ticked the box at sign-up confirming a parent or guardian has given permission.
- Your learning content: the words you add, quiz and game scores, progress, favourites and activity in the App.
- Plan and payment details: your plan (Free, Normal, Pico Ultra or Student plan), whether you pay monthly or yearly, any promo code you used (such as FUNSPANISH26), payment status, renewal and cancellation dates, your Stripe customer reference, and a record (with date and time) that you ticked to start your subscription straight away. Payments are processed by Stripe, and we never see your full card details.
- Pico (AI helper): what you type or say to Pico, Pico's replies, and usage counts (for example to apply the free try and the fair-use limit). If you speak to Pico, your voice is turned into text.
- Student plan: if you have lessons with us, a note that you've been given the Student plan.
- Email choices: whether you ticked the box to get emails from us, and the date and time you did so or unsubscribed.
When you join our emails or get free downloads
- Your email address (and first name, if you give it), what you downloaded, and whether you agreed to marketing emails, with the date and time.
When you book lessons
- The learner's name and age, a parent's or guardian's name and contact details (for learners under 18), lesson dates, notes on level and progress, and payment records.
When you contact us
- Whatever you include in your message, and our reply.
Automatically, when you use the Shop or App
- Technical and usage data: IP address, device and browser type, pages viewed, approximate location (from your IP address), the website that sent you to us, and how you use the Shop or App. Some of this is collected with cookies (see section 9).
We don't ask for sensitive "special category" information (such as health, religion or ethnicity). Please don't put sensitive personal information into your word lists or Pico messages.
4. How we use your information and our lawful bases
UK data protection law (the UK GDPR and the Data Protection Act 2018) says we need a "lawful basis" for each use.
| What we do | Lawful basis |
|---|---|
| Process orders, deliver downloads, post physical packs, handle returns and refunds | Contract |
| Create and run your App account, store your words and progress, provide learning content | Contract (our App Terms) |
| Manage subscriptions and payments through Stripe, apply the Free plan, promo codes and the Student plan | Contract |
| Send service emails: sign-in codes, receipts, payment problems, reminders before a free month ends or a yearly plan renews, and important changes to our terms or prices | Contract and legal obligation. These aren't marketing, so they're sent even if you haven't opted in to marketing emails. |
| Provide Pico (sending what you type or say to our AI provider to create replies) | Contract (a feature you choose to use) |
| Check age, record parent or guardian permission and restrict 18+ content | Legal obligation and legitimate interests (protecting children) |
| Arrange and run lessons | Contract; legitimate interests (learner safety and progress) |
| Answer questions and complaints | Legitimate interests (helping our customers) |
| Keep accounting and tax records | Legal obligation |
| Keep the Shop and App secure and prevent fraud, misuse and file-sharing | Legitimate interests |
| Understand how the Shop and App are used so we can improve them | Consent for non-essential cookies; otherwise legitimate interests |
| Marketing emails from the App: Spanish tips, app news, follow-up emails and offers, including offers to upgrade to a paid plan | Consent, only if you tick the box at sign-up. The box is never ticked for you. Unsubscribe anytime with the link in every email. |
| Marketing emails to Shop customers about similar products | Consent, or the "soft opt-in" if you didn't opt out when you bought. Unsubscribe anytime with the link in every email. |
We don't sell your personal information, we don't show adverts in the App, and we don't make decisions about you based only on automated processing that have legal or similarly significant effects. We don't send upgrade offers to users under 18.
5. Pico, our AI helper
Pico uses Google's Gemini artificial intelligence service to answer questions and help you practise. Some App content is also created or checked with the help of AI.
- When you use Pico, what you type or say (and relevant context, such as the words you're practising) is sent to Google to create a reply.
- Under Google's terms for paid business use of Gemini (which also apply to all use from the UK), Google doesn't use Pico messages or replies to improve its products or train its AI models. Google acts as our data processor and keeps messages and replies only for a limited time, to detect and prevent misuse and to meet legal requirements.
- AI can make mistakes. Pico's answers are created automatically and may be wrong. Check important things with your teacher.
- Please don't share personal information (full name, address, school, phone number, passwords or anything sensitive) with Pico.
- Free users get one free try of Pico. Pico is included in Pico Ultra and the Student plan, with a fair-use limit of 300 messages a month (the current limit is always shown in the App).
- We only look at Pico conversations when we need to fix problems, investigate misuse or keep users safe.
6. Who we share information with
We only share information with service providers who help us run the business, under contracts that require them to protect it, or where the law requires it:
| Provider | What for | Where |
|---|---|---|
| Glide | Hosts the App, stores App data and sends App sign-in codes | USA |
| Stripe | App subscription payments and the "Manage subscription" portal | Ireland / USA |
| Gemini AI for Pico; Google Drive for App files; our business email | USA / EU | |
| Make.com | Automations that pass information between our tools (for example updating your plan after a payment, or adding you to our email list if you opted in) | EU / USA |
| Shopify | Hosts the Shop, checkout, orders, payments and download delivery | Ireland / Canada / USA |
| Email service provider | Sending emails you've agreed to | USA / EU |
| Video hosting provider | Videos shown in the App and Shop | USA |
| Royal Mail | Delivering physical packs (name and address) | UK |
| Accountant / HMRC | Tax and accounting | UK |
We may also share information if the law requires it, to protect someone's safety, or if the business is reorganised or sold (for example if Fun Learning Spanish becomes a limited company).
7. International transfers
Some providers store or process data outside the UK, mainly in the USA and EU. When that happens we rely on UK adequacy regulations (for example for the EU, or for US companies certified under the UK Extension to the EU–US Data Privacy Framework), or on the UK International Data Transfer Agreement or Addendum included in these providers' terms. Contact us for more detail.
8. How long we keep information
| Information | How long |
|---|---|
| Orders, invoices, payment, subscription and refund records | 6 years after the end of the tax year (HMRC requirement) |
| App account, your words and progress | While your account is active. If you delete your account, we delete it within 30 days. Accounts with no use for 24 months are deleted after a reminder email. |
| Pico conversations | 90 days, unless needed longer to investigate misuse |
| Records of your email consent | While you're on our list, then 2 years after you unsubscribe |
| Marketing email list | Until you unsubscribe (we then keep your email on a "do not contact" list) |
| Lesson records | While lessons continue, then 2 years (payment records 6 years) |
| Customer service emails | 2 years |
| Analytics data | Up to 26 months |
| Backups | Deleted on a rolling basis within 35 days |
9. Cookies and similar technologies
- Strictly necessary (always on): keep your basket, checkout and sign-in working and secure.
- Analytics (only with your consent, unless covered by the UK exemption for low-risk statistics): help us understand how the site is used.
- Marketing (only with your consent): for example social media pixels, if we use them.
You can accept or reject non-essential cookies using the cookie banner on the Shop and change your mind anytime using the "Your privacy choices" link at the bottom of the page. See Shopify's cookie information at shopify.com/legal/cookies. In the App, Glide and Stripe use cookies needed for sign-in, payments and to run the App.
10. Your rights
You have the right to:
- access a copy of your personal information;
- correct inaccurate information;
- delete your information;
- restrict or object to certain uses (and always to direct marketing);
- data portability, meaning a copy of the data you gave us (such as your word lists) in a reusable format;
- withdraw consent at any time, for example with the unsubscribe link in any email.
To use any of these rights, email info@funlearningspanish.com. We'll reply within one month (we may need to check your identity), and it's usually free. Parents and guardians can make requests for their children. You can also ask us to delete your App account by emailing us.
11. Children and young people
The App is for learners of all ages, including children and teenagers (for example GCSE students). We follow the ICO's Age Appropriate Design Code (Children's Code):
- Date of birth: we ask for it at sign-up.
- Under 18s: may only use the App with a parent's or guardian's permission, and must tick a box to confirm this before continuing.
- Paid plans must be bought by a parent or guardian aged 18 or over.
- 18+ content: some optional packs (such as Swear Words) are for adults only and are locked for anyone under 18.
- Lessons are for learners aged 7 and over, and we deal with a parent or guardian for anyone under 18.
- Privacy is high by default: no public profiles, no chat between users, no location tracking, no advertising, and no marketing profiling or upgrade offers aimed at children. Under-18s should only sign up for our emails with a parent's or guardian's permission.
- If you think a child has given us information without the right permission, contact us and we'll delete it.
Shop purchases must be made by adults (18+).
12. Keeping information secure
We use reputable providers with strong security, sign-in by one-time email code (so we never hold App passwords), HTTPS encryption and limited access (only the owner of Fun Learning Spanish can see customer data). No system is 100% secure. If a data breach puts you at high risk, we'll tell you and, where required, the ICO.
13. The short version (for younger learners)
- We know your email address so you can sign in, and your date of birth so we can keep you safe.
- If you're under 18, a parent or guardian needs to say it's OK for you to use the App.
- We save your words, scores and progress so you can keep learning.
- If you talk to Pico, what you type or say goes to Google's computers so Pico can answer. Pico can get things wrong, and don't tell Pico private stuff like your address, school or phone number.
- We don't sell your information and we don't show you adverts.
- We only send you emails about Spanish tips if you (with your parent's OK) tick the box, and you can stop them anytime.
- You or your parent can ask us to see or delete your information anytime: info@funlearningspanish.com.
14. Complaints
If you're unhappy with how we've used your information, please contact us first at info@funlearningspanish.com and we'll try to put it right. You can also complain to the Information Commissioner's Office (ICO): ico.org.uk/make-a-complaint, helpline 0303 123 1113.
15. Changes to this policy
We'll update this policy when our services or the law change, and update the "Last updated" date. If we make important changes, we'll tell you by email or in the App.