What we do with your data

This page explains what personal data Agnetia processes, what for, for how long and who it is shared with. It is written to be read in full: if something is unclear, that is a defect of this page and we would like to hear about it.

Version of 20 September 2026

The controller's identifying details are not published yet. Agnetia is operated by a company registered in Spain; its legal name, tax number, address and contact email will be published here as soon as they are completed. In the meantime, the rights described on this page are exercised from Support, inside your account, and are handled within the same statutory deadline.

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Who processes your data

Controller: Not published yet
Tax number: Not published yet
Address: Not published yet
Contact: Not published yet

The controller is the company registered in Spain that operates Agnetia. No data protection officer has been appointed: the processing meets none of the cases that require one under article 37 of Regulation (EU) 2016/679 (GDPR) or article 34 of Spanish Organic Law 3/2018 (LOPDGDD).

The supervisory authority is the Spanish Data Protection Agency, the AEPD (www.aepd.es).

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What data we process

The full list. If a piece of data is not here, it is not processed.

Data	Where it comes from
Email address	You provide it when you sign up. It is your username
Name	You provide it when you sign up
Password	You choose it. It is stored hashed with no way back: nobody can read it
Google identifier and profile picture	Only if you sign in with Google, and only what Google returns when verifying your identity
Native language, language studied and level	You choose the languages; the level is calculated by the platform from your conversations
Learning progress	Generated as you use the platform: what you got right, what you are reviewing, which phase you are on
Transcript of what you say in each turn	Generated as you speak. The audio is not kept; the transcript is, for thirty days
Wallet balance and usage	Generated as you use the platform and as you pay
Card brand and last four digits	Returned by the payment provider. The full number never reaches our systems
Billing address and tax number	You provide them on the payment provider's screen and they stay on your record there; this database does not copy them
IP address, browser and date of access	Logged by the system in a security history when you sign in, change your password or delete your account
The tickets you open in Support	Whatever you write and the files you attach

No special categories of data are processed — health, beliefs, ethnic origin, biometrics — no profiling with legal effects is carried out, and there are no automated decisions that significantly affect you. The level the platform estimates is an indicative teaching assessment that only you see.

No data is bought or enriched from outside sources: everything above comes from you or from your own use of the service.

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What we use it for, and on what legal basis

Purpose	Legal basis
Creating and maintaining your account, verifying your email and giving you access	Performance of the contract (art. 6(1)(b) GDPR)
Providing the service: asking, listening, correcting and saving your progress	Performance of the contract
Charging the fee and top-ups, and issuing invoices	Performance of the contract, and legal obligation for invoicing (art. 6(1)(c))
Sending you service emails: verification, password reset, deletion confirmation and payment notices	Performance of the contract
Handling the tickets you open	Performance of the contract
Keeping a history of sign-ins and sensitive operations to detect fraud and abuse	Legitimate interest in the security of the service and of accounts (art. 6(1)(f))
Keeping turn transcripts for thirty days so a disputed correction can be reviewed and the agent's quality measured	Legitimate interest in service quality and traceability (art. 6(1)(f))
Keeping invoices and accounting records	Legal obligation (art. 6(1)(c))

No purpose relies on your consent, because none needs it: no marketing messages are sent, no data is shared for advertising, and there are no analytics or advertising cookies. If anything of that kind were ever added, consent would be asked for beforehand and separately.

Where the basis is legitimate interest you can object to the processing, and the objection will be upheld unless compelling grounds override it. For the security history such grounds usually exist: it is what makes it possible to show who got into an account.

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Your voice and your conversations

It is the most sensitive data that passes through here, so it gets its own section and the detail it deserves.

The audio of what you say is not stored. It is sent to the transcription service, turned into text and discarded. There is no recording of your voice kept anywhere, not even briefly once the turn ends.
The model that decides what to say back never receives the audio: it receives the transcribed text. That is what keeps your voice from travelling beyond the transcription step.
Each turn's transcript is kept in an audit log that is deleted after thirty days. It exists so a correction you dispute can be reviewed, and so the agent's teaching can be measured.
The agent reads from your record only what the turn needs — your name, the two languages, the chosen voice and what you have demonstrated so far — and it cannot delete your progress or your history.
What you say is always treated as data, never as instructions: asking the agent to change your progress or ignore its rules changes nothing.
The level the platform estimates from your conversations is never said out loud and never returns to the conversation. You look it up in your profile, and nobody else does.

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Who it is shared with

Nobody buys your data, and none is handed to third parties for their own purposes. What there is are providers who process data on Agnetia's behalf so the service can work, each under a data processing agreement.

Provider	What for	What it receives
Stripe	Payment, invoicing and tax calculation	Your email, your billing details and your payment method details, which you type directly on its page
OpenAI	Voice transcription, the text model that decides the reply, and speech synthesis	The turn's audio in order to transcribe it, and the turn's text with the minimum context of the exercise
Resend	Sending service emails	Your email address and the content of the message
Railway	Hosting the platform and the voice agent	The infrastructure everything above runs on
Managed database provider	Database storage	The data in the table above, except what only exists at Stripe
Google	Only if you use Sign in with Google, to verify your identity	The sign-in request. Google receives nothing about your activity in Agnetia

The artificial intelligence models are configurable and the provider can change without the agent's behaviour changing. If it changes, this table changes with it and the date above reflects that.

Beyond these providers, data may be disclosed to public authorities, courts or law enforcement where a legal rule requires it.

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Transfers outside the European Economic Area

Some of the providers above are companies headquartered outside the European Economic Area, or may process data on servers located outside it.

Where that happens, the transfer relies on one of the mechanisms in chapter V of the GDPR: an adequacy decision of the European Commission — such as the EU-US Data Privacy Framework for certified providers — or the standard contractual clauses approved by the Commission, together with whatever supplementary measures are appropriate.

You can ask us, through the contact channels, which specific mechanism covers each provider.

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How long it is kept

Data	Retention
Your account and your progress	For as long as the account exists. Deleting it removes them along with your vocabulary, exercise profiles and open sessions
Audio of your turns	Never kept, at any point
Turn transcripts	Thirty days
History of sign-ins and sensitive operations	Kept so that what happened in an account can be shown. Deleting the account unlinks it from you: the entry survives without a user identifier
Open sessions	The session token lasts thirty days and rotates on every use. They are removed on sign-out, on password change and on account deletion
Invoices and accounting records	The statutory retention period for commercial and tax records, which in Spain reaches six years. They are held by the payment provider
Support tickets	For as long as the account exists, and afterwards for as long as needed to handle a claim

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Your rights

Access: to know what data about you is processed and get a copy.
Rectification: to correct anything inaccurate. You can correct your profile details yourself at any time.
Erasure: to ask for your data to be deleted. You can do it yourself from the platform, without asking permission: deletion is confirmed with a link sent to your email and cancels your subscription first.
Restriction: to ask for data to be kept but not used, while a disagreement is resolved.
Portability: to receive the data you gave us and the data you generated, in a structured, commonly used format.
Objection: to object to processing based on legitimate interest.
Withdrawing consent: today no processing relies on it, but if any ever did, you could withdraw it at any time without affecting what came before.

Rights are exercised through the contact channels in the first section, or from Support inside your account. We answer within one month, extendable to two if the request is complex, and it is free unless requests are manifestly unfounded or excessive.

To stop someone exercising your rights in your name, an additional identity check may be requested when a request does not come from the account concerned.

If you believe the processing does not comply with the rules, you can complain to the Spanish Data Protection Agency (www.aepd.es). We would appreciate the chance to sort it out first, but it is not a requirement.

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How it is protected

All traffic travels encrypted, and the server declares that it may only be spoken to that way.
Passwords are stored hashed with no way back: nobody inside Agnetia can read them.
The browser session is stored in a way the page's own code cannot read, and it does not travel anywhere else.
Your card number is not in these systems, so it cannot leak from them. The full detail is on Payment security.
Database access uses a role limited to the application's own tables, not an administrator account.
There are attempt limits on sign-in, sign-up and password recovery, and a history of sensitive operations.

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Minors

The service is not aimed at children under fourteen and should not be used by them.

Subscribing requires legal capacity to do so: if you are under the age of majority, you need authorisation from whoever holds parental responsibility or guardianship, and that person takes on the contract.

The platform does not verify age at sign-up. If we find out, or are told, that an account belongs to a child under fourteen, it will be deleted along with its data.

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Changes to this policy

This policy may be updated when the service, a provider or the rules change. The version in force is always the one published here, with the date shown above.

If a change substantially affects how your data is handled, you will be told by email before it takes effect.