BlulingoPrivacy Policy
This policy is written in English only so that one text governs, in every country. It describes what the app actually does.
1. Who is responsible for your data
Blulingo (“we”, “us”) is the controller of the personal data described in this policy, within the meaning of Article 4(7) of the General Data Protection Regulation (EU) 2016/679 (“GDPR”).
For any question about this policy or about your data, contact us at support@blulingo.online. We answer data subject requests within one month, as required by Article 12(3).
2. What we collect, why, and on what legal basis
We collect as little as the app can work with. Each item below names the purpose and the lawful basis under Article 6(1).
Account: email address
Used to create your account, sign you in, verify your address and let you reset your password. If you sign in with Google we receive your email address and the Google account identifier from Google; we do not receive your Google password.
Legal basis: Article 6(1)(b) — performance of the contract you enter into by creating an account.
Password
Handled entirely by Google Firebase Authentication. It is not transmitted to, stored by, or visible to us at any point.
Display name and profile picture
Only if you set them. They are shown to other users when you are matched for a video call or a word duel, and in your conversations, so that the person on the other side knows who they are speaking to.
A profile picture you upload is stored on our own servers in the European Union. Before it is written to disk it is decoded and re-encoded, which removes all metadata the original carried — including GPS coordinates, device identifiers and timestamps — and resized to 256 pixels. The stored file has a random name that cannot be derived from your account, so pictures cannot be enumerated. Removing your photo, or deleting your account, deletes the file.
Legal basis: Article 6(1)(b).
Account record and moderation decisions
We keep one record per account on our own servers in the European Union. It holds your account identifier and email address, your display name and profile picture if you set them, which language you are learning and from which, when you registered, when the app was last opened, your operating system and the app version. This is what lets us operate the service: answer a support request, see that the app is working, and act on a report about a specific account rather than about nobody in particular.
If a decision is taken about your account — it is suspended, reinstated, or given a subscription — we record the decision, its reason, the time, and which member of staff made it. Staff logins to our administration tool are recorded with their IP address. Both exist so that a decision about you can be reviewed and explained rather than merely asserted.
Legal basis: Article 6(1)(b) for operating your account, and Article 6(1)(f) — our legitimate interest in keeping the service safe and in being able to account for moderation decisions.
Advertising
The free version shows occasional ads, supplied by Google AdMob. A subscription removes them entirely — that is what the subscription is for, and no ad is requested at all for an account that has one.
Ads are never shown during a video call or inside a lesson. They appear between pieces of work, after a lesson has finished.
To choose which ads to show, Google may use an advertising identifier held by your device and coarse information such as your approximate region and device type. We do not send Google your account, your email address, your messages, your lessons or anything you say. If you are in the European Economic Area or the United Kingdom you are asked first, through Google's own consent form, and nothing personalised is requested unless you agree; you can change that answer at any time from the same form. Google's use of this data is described in its own privacy policy at policies.google.com.
Legal basis: Article 6(1)(a) — your consent, where consent is required; Article 6(1)(f) for a non-personalised ad, which needs no identifier.
Notifications
If you turn on message notifications, we store an address for this device — a token issued by Firebase Cloud Messaging — so that we can reach it when the app is closed. It is stored on our own servers, alongside your account, and is deleted when you turn notifications off, sign out, or uninstall the app.
A notification says who wrote to you and nothing else: their display name, and the words “Sana bir mesaj gönderdi”. The message itself is never put in it. A notification travels through Google’s servers and appears on your lock screen, so putting private text in one would disclose it both to Google and to anyone standing behind you.
The daily study reminder is scheduled on your own device and involves no server and no third party at all.
Legal basis: Article 6(1)(a) — your consent, given when you turn notifications on and withdrawable at any time from Settings.
People you have blocked
When you block someone, we store the pair of account identifiers on our own servers in the European Union. It has to be held there rather than on your phone: matching, messaging and duel invitations are all decided on our servers, so a block kept only on your device would be a rule the other person's device is not following.
We store who blocked whom and when, and the reason if the block came from a report. The person you blocked is never told. Removing a block deletes the record.
Legal basis: Article 6(1)(f) — our legitimate interest, and yours, in letting you stop someone from contacting you.
Profile picture screening
Every profile picture is checked for nudity before it is stored. The check runs on our own server, on the resized copy, and takes a fraction of a second; the picture is not sent to any third party and no copy is kept if it is refused — a rejected photo is never written to disk at all. We store the outcome, not the image.
Legal basis: Article 6(1)(f) — our legitimate interest in not distributing sexual images to other users, some of whom are sixteen.
Learning progress
Completed topics, saved words, review schedules, streak and study time are stored on your own device. They are not uploaded to us and we cannot read them.
Duel rating
If you play a word duel, we store a pseudonymous player identifier, your display name, your rating and the number of games played. This is what makes a ranking possible.
Legal basis: Article 6(1)(b).
Text sent for lessons, dictionary lookups and speech
When a lesson, a word explanation or spoken audio is generated, the text and the language pair are sent to our server. These requests carry no account identifier: the generated material is stored in a shared pool keyed by language and level so that the next learner receives it instantly, and it cannot be traced back to you.
Legal basis: Article 6(1)(b).
Microphone
Used for video calls, and for nothing else. No lesson or exercise records you: speech recognition was removed from the app entirely, so there is no audio to upload, none to store, and nothing for us to delete. Exercises that once asked you to speak now ask you to listen and write.
In a call the audio travels directly to the other person and never through our servers.
Legal basis: Article 6(1)(a) — your consent, given through the system microphone permission, which you may withdraw at any time in your device settings.
Camera and video calls
Video and audio in a call travel directly between the two devices (WebRTC, peer-to-peer). Our signalling server sees only what is needed to connect you: a temporary connection identifier, the language you want to practise, and a yes/no flag saying whether a face is currently visible so the other side knows whether to lift the blur. Face detection itself runs on your device. We never receive, record or store a single frame.
When both devices are behind restrictive networks, the encrypted stream is relayed through our TURN server, which forwards it without being able to read it and keeps no copy.
Legal basis: Article 6(1)(a) for camera and microphone access; Article 6(1)(b) for the matching itself.
Private messages
Messages you send to another user are stored on our servers. They have to be: a message sent to somebody who is offline has to wait somewhere until they open the app.
What we store is the text, who sent it, who it was for, when it was sent, and when it was read. Messages are not scanned, not analysed, not used to train anything, and not shared with anyone.
Deleting a conversation removes it from your side. The other person keeps their copy, because a message they received is theirs — we cannot take it back from them, and would not.
Only people who have added each other as friends during a video call can message each other, so a stranger cannot write to you.
Legal basis: Article 6(1)(b).
Friend list
Who you are friends with is stored on your device, not on our servers. We can see that two identifiers have exchanged messages, which is unavoidable if messages are to be delivered, but we hold no list of who knows whom.
Reports of other users
If you report someone during a call, we store the reason, the temporary connection identifiers of both sides and the time. This is kept for up to 12 months so that repeated abuse can be acted on.
Legal basis: Article 6(1)(f) — our legitimate interest, and that of every other user, in keeping the service safe.
Purchases
Subscriptions are processed by Google Play or the Apple App Store. Your card details go to them, never to us. We receive only the fact that a subscription is active and when it renews.
Legal basis: Article 6(1)(b), and Article 6(1)(c) for the tax records we are required to keep.
3. What we do not do
- We do not sell your personal data.
- We do not show advertising and we carry no advertising SDK.
- We do not profile you for marketing, and no decision about you is made by automated means within the meaning of Article 22.
- We do not record your voice or your video.
- We do not read, scan or analyse your messages.
- We do not track you across other companies’ apps or websites.
4. Who else processes your data
We use the following processors under Article 28. Each acts only on our instructions.
- Google Ireland Ltd. — Firebase Authentication (account and sign-in).
- Google LLC / Apple Inc. — payment processing for subscriptions.
- Hostinger International Ltd. — hosting of our servers within the European Union.
- Google LLC — the language model that writes lesson material. It receives the lesson topic and language pair only; no account identifier is included.
Where a processor transfers data outside the European Economic Area, that transfer is covered by the European Commission’s Standard Contractual Clauses under Article 46(2)(c).
5. How long we keep it
- Account data: until you delete your account.
- Duel rating and display name: until you delete your account.
- Private messages: until you delete your account. Deleting your account erases every message you sent.
- Profile picture: until you remove it or delete your account.
- Abuse reports: up to 12 months.
- Blocks: until you remove the block or delete your account.
- Notification device address: until you turn notifications off, sign out, or uninstall.
- Moderation decisions about your account, and staff login records: up to 24 months.
- Generated lesson material: indefinitely — it contains no personal data and is shared by all learners.
- Learning progress on your device: until you delete it or uninstall the app.
When you delete your account, your account record, display name, profile picture, duel rating and every message you sent are erased within 30 days. What other people wrote to you stays in their own conversation, because it is their data and not yours to erase. Abuse reports, and the record of a suspension, are kept for their retention period because they concern the safety of other people, as permitted by Article 17(3) — an account closed for harming someone must not be reopenable by deleting it and starting again.
6. Your rights
Under the GDPR you have the right to:
- Access — obtain a copy of the personal data we hold about you (Article 15).
- Rectification — have inaccurate data corrected (Article 16).
- Erasure — have your data deleted (Article 17). You can do this yourself: Profile → Account → Delete account.
- Restriction — ask us to limit how we use your data (Article 18).
- Portability — receive your data in a machine-readable format (Article 20).
- Objection — object to processing based on legitimate interest (Article 21).
- Withdraw consent at any time, without affecting the lawfulness of what was done before (Article 7(3)).
To exercise any of these, write to support@blulingo.online. You also have the right to lodge a complaint with a supervisory authority in the country where you live or work (Article 77).
7. Children
Blulingo is not intended for children under 16. We do not knowingly collect data from them. If you believe a child has created an account, write to support@blulingo.online and we will delete it.
8. Security
All traffic between the app and our servers is encrypted with TLS. Video and audio in a call are encrypted end to end by WebRTC (DTLS-SRTP). Every endpoint that touches your own data requires a signed identity token, which our servers verify against Google’s published keys — we never accept an identity that a client simply claims. Passwords are never handled by us.
9. Purchases and subscriptions
These terms apply to every paid subscription.
- Subscriptions are offered monthly or yearly. The price, the currency and the renewal date are shown before you confirm.
- Payment is taken by Google Play or the Apple App Store, under their terms. We never see your card details.
- A subscription renews automatically at the end of each period unless you cancel at least 24 hours before it ends.
- You cancel through the store you bought it from — Google Play Subscriptions, or Apple Settings → Subscriptions. Deleting the app does not cancel a subscription.
- Cancelling stops the next renewal. The current period runs to its end and is not refunded pro rata.
- If you are a consumer in the European Union you have a 14-day right of withdrawal under Directive 2011/83/EU. By starting to use a paid feature within those 14 days you ask for immediate performance and, under Article 16(m), lose that right for content already supplied.
- Refunds are handled by the store that took the payment. We can ask them to issue one but cannot issue it ourselves.
- If we change the price, the change applies from the next renewal and you are told before it takes effect. You may cancel instead of accepting it.
- Free features stay free. What a subscription adds is described on the subscription screen at the time you buy.
10. Changes to this policy
If we change how we handle personal data, we update this page and the date at the top. Changes that reduce your rights or widen what we collect are notified in the app before they take effect.
support@blulingo.online