Hola Calle

Privacy Policy

This policy explains how Hola Calle collects, uses and protects your personal data when you use our mobile app.

Last updated: September 30, 2026

1. Who we are

Hola Calle is operated by Comm.V Lorem, a company registered in Belgium. If you have questions about this policy, contact us at hola@holacalle.com.

2. What data we collect and why

Account data

When you sign in with Google or Apple, we receive your email address and a unique user ID. This is required to create and maintain your account. Without it you cannot use the app. If you sign in with Apple and choose "Hide My Email," we receive a private relay email address (@privaterelay.appleid.com) instead of your real email; this works the same way for your account.

Learning progress

We store your lesson completions, flashcard history, daily streaks, and in-app activity. This is required to deliver the core learning experience - your progress would be lost without it.

Voice data (Lola feature)

When you use the Lola AI conversation feature, your voice is captured via your microphone, converted to text, and used to generate a reply. Voice audio is processed ephemerally - it is not stored after transcription. This feature is optional; you can use Hola Calle without ever using Lola.

Subscription and purchase data

We use RevenueCat to manage subscriptions. RevenueCat receives your device ID and purchase history to determine your entitlements. We do not store your payment card details.

Crash reports and error logs (Sentry)

We use Sentry to collect crash reports and error logs to fix bugs. No personally identifiable data, app content, or user messages are included. Sentry receives a technical breadcrumb trail of anonymous in-app actions (e.g. "paywall opened", "daily focus completed") alongside crash stack traces.

Attribution and marketing analytics

We use Meta's attribution SDK to measure whether users who saw our ads on Facebook or Instagram installed the app. This sends a hashed device identifier and app install event to Meta. No browsing history, message content, or learning activity is shared with Meta. On iOS, we do not access the Apple Advertising Identifier (IDFA) unless you grant tracking permission.

Device identifiers

A device identifier is used by our subscription provider (RevenueCat) and Google Play Services for app functionality and analytics. This is collected automatically.

Referral links (partners, friends and campaigns)

When you open a Hola Calle referral link, our server records the link code, your device platform (iOS, Android or other), a coarse browser type and the time. To connect a first install on iOS to that tap, we also keep a hashed form of your network address (IP address). It cannot be turned back into your IP address, it is used only for this match, and it is deleted after 7 days. If the app matches your install to the link, the owner of the link (a partner or a friend) is credited when you subscribe, and we record that connection on your account. The owner of a link only sees totals in the app, such as the number of taps and sign-ups, not who you are.

Buddies (optional social feature)

If you use Buddies, we store the nickname and avatar you choose, the buddy invites you create or accept, and who you are connected to (up to 5 people who already know you). Your buddies can see your nickname, your avatar, whether you practised today, how many days you practised in the past week and, only if you switch it on, your current streak. They cannot see what you studied, and there is no chat: buddies can only send each other one of three preset cheer-on messages, delivered as a notification. To work out "today" correctly we also store your device time zone. Nicknames you type yourself are visible to your buddies, so please do not use your real name or personal details. You can turn off activity sharing, streak sharing and buddy notifications at any time in the Buddies settings.

Buddies: 7-day comparison chart

The Buddies screen can show a small chart comparing how many of the last 7 days you practised with your buddies' average, your most active buddy, or any single buddy you pick. Because the chart is built day by day, your buddies can see on which of those days you practised. Only buddies who have activity sharing switched on are included, and switching off "Share my activity" removes you from their charts. The chart can also show how many practice sessions you and each of those buddies finished in the last 7 days.

Buddies: challenges

If you start or join a buddy challenge, we store the challenge (its goal, deadline and who took part) and a simple record of which finished practice sessions you did, by kind (speaking, listening, Daily Focus, and games and reviews), with the time each was finished. Everyone who joins a challenge can see, for that challenge only, each other's nickname, avatar and how many sessions of each kind they did during it, even if they are not each other's buddies. Nothing else about your practice is shared, and there is no chat. You can leave a challenge at any time. Challenge and practice records are deleted with your account and included in your data export.

Partner program: payout details (partners only)

If you take part in our partner program, we store the payout details you enter in the app: your name or company name, your country and address, your IBAN and, for a business, your VAT number. We also store the commission earned on the people you refer and whether it has been paid out. We use this only to pay you, to book your invoice and to meet our accounting and tax obligations. Only you and authorised members of our team can see it. If you enter a VAT number, we send it to the European Commission's VIES service to check that it is valid.

Buddy safety: mute, remove, block and report

You can mute or remove a buddy, block a person, and report a nickname that breaks our rules. Blocks and mutes are private to you. When you report someone we store the report (who reported whom, the reason and any note you add) so we can review it and keep the community safe. We may reset a nickname or suspend access to Buddies for accounts that break the rules.

3. Legal basis (GDPR)

We are subject to EU/EEA data protection law. Our legal bases are:

  • Contract performance - account data and learning progress are necessary to provide the service you signed up for
  • Legitimate interests - crash logs and diagnostics help us maintain a functioning app
  • Legitimate interests - matching a referral link tap to an install so that partners and friends are credited correctly
  • Consent - voice data (Lola) is only processed when you actively choose to use that feature
  • Consent - Buddies is optional; what your buddies can see is your choice and can be switched off at any time in the app
  • Contract performance and legal obligation - partner payout details are needed to pay you, and payment records must be kept for accounting and tax purposes

4. Who we share data with

We do not sell your data. We share data only with the following processors:

ProcessorPurposeLocation
SupabaseDatabase and file storageEU (AWS Frankfurt)
Google / Apple (Sign-In)AuthenticationGlobal
RevenueCatSubscription managementUSA
OpenAIVoice transcription (Lola only)USA
Google PlayCrash reporting, app deliveryGlobal
SentryCrash and error monitoringUSA
Meta (Facebook)Ad attribution (install measurement)USA
European Commission (VIES)VAT number validation (partners only)EU

All processors are bound by data processing agreements. Transfers outside the EU are covered by Standard Contractual Clauses.

5. How long we keep your data

  • Account and learning data - retained for as long as your account is active
  • Voice data - not retained; discarded immediately after transcription
  • Crash logs - retained for up to 90 days
  • Attribution data - retained according to Meta's standard retention policy, typically around 180 days
  • Referral link taps - the hashed network address is deleted after 7 days; the tap record (code, platform, time) is kept without it so partners can see their tap totals, and it is no longer linked to you once your account is deleted
  • Buddy data (profile, connections, blocks, reports) - kept while your account is active and deleted with your account. Removing a buddy ends what they can see immediately; a record of the removal is kept so that blocks and reports stay effective
  • Partner payout details - your IBAN and address are deleted with your account. Records we must keep for accounting and tax purposes (your name or company name, country and VAT number, and the commissions and payments with their amounts and dates) are kept for as long as Belgian accounting and tax law requires
  • Deleted accounts - all personal data is permanently deleted within 30 days of account deletion, except records we are legally required to keep (see partner payout details above)

6. Your rights (GDPR)

As an EU/EEA resident you have the right to:

  • Access - request a copy of your data
  • Deletion - permanently delete your account and all associated data
  • Portability - export your data in a machine-readable format
  • Rectification - correct inaccurate data
  • Objection - object to processing based on legitimate interests

You can exercise your right to deletion and export directly in the app: Profile → Your data.

To exercise any other right, email hola@holacalle.com. We will respond within 30 days.

You also have the right to lodge a complaint with your national data protection authority. In Belgium: Gegevensbeschermingsautoriteit (GBA).

7. Security

All data is transmitted over encrypted connections (HTTPS/TLS). We follow industry-standard practices to protect your data at rest and in transit.

8. Children

Hola Calle is intended for users aged 18 and older. We do not knowingly collect data from children under 16. If you believe a child has provided us with personal data, contact us at hola@holacalle.com.

9. Changes to this policy

We may update this policy as we add new features. We will notify you of material changes through the app or by email. The date at the top of this page reflects the most recent update.

10. Contact

Comm.V Lorem

hola@holacalle.com

Last updated: September 30, 2026