Sankofa Twi — Privacy Policy
Last updated: 30 June 2026

1. DATA CONTROLLER
The data controller responsible for processing your personal data is:
• Legal name: Lourette Osei Bonsu
• Trading name: Sankofa Twi
• Registered address: Carrer de Maignon 34, 08024 Barcelona, Spain
• Tax ID (NIE): Y0153486K
• Email (privacy): sankofa@aparato.ai
• Data Protection Officer: Not appointed

If you are in the EU/EEA and have questions about how we handle your data, you can contact us using the details above.

2. WHAT PERSONAL DATA WE COLLECT
(a) Information you give us
• Account data: email address and display name; and, if you sign in with Google, the basic profile information Google shares with us.
• Optional profile data: date of birth and gender (you choose whether to add these).
• Content you submit: text you type into the AI Translate / Twi audio features, and any messages or content you share through social features.

(b) Information created as you use the app
• Learning data: lesson scores, XP, levels, streaks, daily activity, wisdom keys, "pedis" balance, badges, and premium status.
• Leaderboard data: your display name and XP, shown to other users in public rankings.

(c) Information collected automatically
• Approximate location: derived from your IP address solely to display prices in your local currency. We do not store your IP address for this purpose.
• Technical and diagnostic data: basic device and app information needed to operate the service and fix problems.

We do not intentionally collect "special category" data (e.g. health, religion, political opinions). Please do not enter such data into free-text or AI fields.

3. LAWFUL BASES FOR PROCESSING (Article 6 GDPR)
• Performance of a contract (Art. 6(1)(b)): to create and run your account, deliver lessons and progress tracking, operate leaderboards, and process subscriptions and in-app purchases.
• Consent (Art. 6(1)(a)): for optional features and data — optional profile fields, optional social features, and any non-essential analytics or marketing. You may withdraw consent at any time without affecting prior processing.
• Legitimate interests (Art. 6(1)(f)): to keep the service secure, prevent abuse and fraud, and improve and debug the app. You may object (see Section 8).
• Legal obligation (Art. 6(1)(c)): to comply with tax, accounting, and consumer-protection laws.

4. USE OF ARTIFICIAL INTELLIGENCE (AI TRANSPARENCY)
• Provider: GhanaNLP / "Khaya" AI API (translation and text-to-speech).
• What is sent: the specific text you enter into the AI Translate or audio features.
• Purpose: to translate between languages and to generate spoken Twi audio (including phonetic and pronunciation modelling).
• How it works: outputs are generated automatically by language models. AI can make mistakes; results are for learning and should not be relied upon as professionally accurate translation.
• No solely-automated decisions with legal effect (Art. 22 GDPR).
• In line with EU AI Act transparency expectations, we tell you when you are interacting with AI-generated output.

You can use most of the app without using the AI features. If you do not submit text to the AI tools, no text is sent to the AI provider.

5. WHO WE SHARE DATA WITH (PROCESSORS & THIRD PARTIES)
• Google Firebase (Google Ireland Ltd.) — authentication, database, and storage.
• GhanaNLP / Khaya — receives the text you choose to translate or voice.
• ipapi.co — estimates your approximate country from your IP for local pricing.
• Apple App Store / Google Play — process payments and manage subscriptions.
We do not sell your personal data.

International transfers: some providers may process data outside the EEA. Where this happens, we rely on appropriate safeguards such as the European Commission's adequacy decisions or Standard Contractual Clauses (SCCs). You can request a copy of the relevant safeguards using the contact details above.

6. DATA RETENTION
• We keep account and learning data for as long as your account is active.
• If you delete your account, we delete or irreversibly anonymise your personal data without undue delay, except where we must retain certain records to meet legal obligations (e.g. billing/tax records, per Spanish law).
• Backups are cycled out on a rolling basis.
• AI inputs are processed to return your result and are not retained by us to build a profile of you.

7. SECURITY MEASURES
• Encryption of data in transit (TLS/HTTPS) and authentication handled by Firebase Authentication.
• Access controls enforced by database security rules.
• API security for our backend and AI calls.
• Restricted administrative tooling with role-based access.
No system is perfectly secure, but we work to protect your data and will notify you and the competent authority of a personal data breach where legally required.

8. YOUR RIGHTS (Articles 15–22 GDPR; LOPDGDD)
You have the right to: access, rectification, erasure ("right to be forgotten"), restriction, portability, objection, and to withdraw consent at any time; and not to be subject to solely automated decisions producing legal/similar effects.

How to exercise them: use the in-app controls (Profile → edit your data; Profile → Delete account) or email sankofa@aparato.ai. We respond within one month, as required by the GDPR. We may need to verify your identity first.

Right to complain: you may lodge a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos, AEPD), C/ Jorge Juan 6, 28001 Madrid — www.aepd.es — or your local EU supervisory authority.

9. CHILDREN
Sankofa Twi is not directed to children under 14 (the minimum digital-consent age in Spain under the LOPDGDD). We do not knowingly collect data from children under 14. If you believe a child has provided us data, contact sankofa@aparato.ai and we will delete it.

10. COOKIES AND SIMILAR TECHNOLOGIES
The mobile app uses local device storage and identifiers only as needed to run the service (e.g. keeping you signed in, remembering settings). We do not use advertising cookies in the app.

11. CHANGES TO THIS POLICY
We may update this policy from time to time. We will change the "Last updated" date above and, for significant changes, provide a more prominent notice in the app.

12. CONTACT
• Privacy / data protection: sankofa@aparato.ai
• General support: sankofa@aparato.ai
• Postal: Carrer de Maignon 34, 08024 Barcelona, Spain