Privacy policy
This policy explains how Civoo collects and processes your personal data, in accordance with Regulation (EU) 2016/679 (GDPR) and the French Data Protection Act.
The French version is the legally binding one. This English translation is for information only.
Data controller
The data controller is Virginie MINEL (EI), publisher of Civoo, reachable at biinadev@gmail.com. No data protection officer (DPO) has been appointed, as this is not mandatory for a service of this kind; any question about your data may be sent to the same address.
Data we collect
Depending on your use, we process: your email address (account), your chosen track and CEFR level, your answers and progress, your mock-exam sessions, reported questions, your device sessions (to limit account sharing), and your Pass purchases (status, tier and expiry; no card data is stored by Civoo). Anonymous audience statistics are collected via Vercel Analytics.
Purposes
Your data is used to: create and secure your account, remember your track and progress, serve you the right questions, manage Passes and access to paid content, limit abusive account sharing, send the emails needed to run the service, and improve the app. We sell no data.
Legal bases
Performance of the contract (account creation, service and Passes), our legitimate interest (security, fraud prevention, anonymous audience measurement), compliance with legal obligations (invoicing, accounting) and, where applicable, your consent.
Retention periods
Your account and progress data are kept for as long as your account is active, then deleted within 30 days of closure (they may be kept in anonymised form for statistics). Billing data linked to Passes are kept for ten (10) years, in accordance with accounting obligations (article L. 123-22 of the French Commercial Code). Technical and security logs are kept for a maximum of twelve (12) months.
Sub-processors
We use sub-processors: Supabase (authentication, database, data hosting), Vercel (application hosting and audience measurement), Stripe (payment processing) and Resend (email delivery). Some transfers outside the EU may occur, framed by appropriate safeguards (standard contractual clauses).
Your rights
You have the right of access, rectification, erasure, restriction, portability and objection. You can exercise access/portability and erasure directly from your profile (Profile › My data): the export downloads your data as JSON and deletion permanently removes your account. For other requests, write to biinadev@gmail.com. You also have the right to lodge a complaint with the CNIL (www.cnil.fr).
Cookies and trackers
Civoo uses only strictly necessary cookies (authentication session, language preference, device identifier to limit account sharing). Audience measurement is anonymous, with no tracking or advertising cookies; no consent banner is therefore required.