Legal information

Privacy Policy

Modo (“we”, “us”, “our”) operates the Modo mobile application and website (modospanish.com). We value your privacy and are committed to protecting your personal information. This Privacy Policy explains what data we collect, how we use it, and your rights under applicable privacy laws, including the EU General Data Protection Regulation (GDPR).

1. Information We Collect

We only collect information necessary to provide and improve the Modo learning experience.

a. Account and Profile Data

• Email address
• User ID
• Your name, given during onboarding
• Learning progress (lessons completed, XP, streak, settings)

Collected via Supabase (authentication and database). Stored securely in the EU (Supabase EU data center).

b. Usage Analytics

Collected via PostHog for product analytics and feature improvement. Includes:

• Lesson completions and accuracy
• XP and streak data
• Feature usage (e.g. AI Coach interactions, unit test results)

All analytics data is anonymous, uses random UUIDs, and is cookieless. Hosted on EU servers at https://eu.i.posthog.com.

c. Purchases and Subscriptions

Handled by Apple In-App Purchases on iOS, Google Play Billing on Android, and RevenueCat Web Billing for purchases made in the web app, which uses Stripe as its payment processor. RevenueCat manages your subscription status across platforms. Collected data:

• Purchase receipts
• Subscription status and plan type
• Renewal or cancellation events

Payment data is processed securely by Apple, Google or Stripe, per their own privacy policies. We never store or access your credit card details.

d. Notifications

If you enable notifications, we use OneSignal to send reminders and learning updates. Data stored: device token only (no personal data). See OneSignal Privacy Policy.

e. App Hosting and Delivery

App hosting is provided by Vercel, with Cloudflare for content delivery. These providers receive standard request data (such as IP address and browser type) needed to serve the site. No account or learning data is stored with them.

f. Crash Reports and Diagnostics

We use Sentry to collect crash reports and technical diagnostics, so we can find and fix errors. Collected data:

• Crash and error reports, including stack traces
• Device model, operating system version and app version
• The app state leading up to an error

Crash reports contain no payment details. Sentry acts as a data processor on our behalf.

2. How We Use the Data

We use collected information to:

• Authenticate users and manage accounts
• Track progress and personalize learning
• Deliver notifications and reminders
• Handle subscriptions and app access
• Improve Modo's functionality and user experience

3. Data Storage and Security

• All communication is protected by HTTPS encryption
• On iOS, authentication runs natively and tokens are stored in the iOS Keychain
• On Android and the web, authentication runs in the Modo web app and the session is kept in the app's own sandboxed storage, which other apps on the device cannot read
• Tokens automatically rotate and expire regularly
• Databases hosted in EU data centers (Supabase & PostHog)

4. Sharing of Data

Modo has XP leagues, so a name and your XP are visible to the other learners in your league. The first time you open the leaderboard you choose whether to appear under the name you gave during onboarding or under a random anonymous name, so you can take part without being identifiable. Nothing else about your account is shown to other learners.

Beyond that, we only share data with essential third parties, all GDPR compliant:

We never sell your personal information or share it for advertising purposes.

5. Data Retention

Your data is retained only as long as your account is active or as required by law. You may request account deletion at any time (see Section 7).

6. Children's Privacy

Modo is intended for users aged 13 and older. We do not knowingly collect personal data from children under 13.

7. Your Rights (EU / EEA)

You have the right to:

• Access your personal data
• Request correction or deletion
• Object to processing
• Request data portability

To exercise these rights, contact us at [email protected].

8. Changes to This Policy

We may update this policy periodically. Updates will be posted on modospanish.com/legalwith the new “Effective Date”.

9. Contact

For any privacy questions, contact:
Modo — Privacy Team
[email protected]

Deleting Your Modo Account or Your Data

Modo is operated by Wise Ventures B.V.

How to Delete Your Account

In the app

Open your profile, go to Settings and choose “Delete account”.

By email

Write to [email protected] from the email address your account uses, with “Delete account” as the subject. We confirm your request and delete your account within 30 days.

What We Delete

• Your account and profile details (name and email address)
• Your learning progress, streaks and quest history
• Your device and notification data

What We Keep, and for How Long

Deleting Some of Your Data Without Deleting Your Account

You do not have to close your account to have data removed. Write to [email protected] from the email address your account uses, with “Delete my data” as the subject, and tell us what you would like removed. We confirm your request and carry it out within 30 days.

You can ask us to delete any of these on their own:

• Your learning progress, streaks and quest history — your account stays open and you start again from zero
• Your usage analytics
• Your device and notification data — you stop receiving reminders

Your account and email address stay in place, so you can keep using Modo. Purchase and invoice records are the one exception: we have to keep those for the period set out in the table above.

Terms of Use

These terms govern your use of Modo: the iOS app, the Android app and the web app at web.trymodo.app. By creating an account or using Modo you agree to them.

1. Who We Are

Modo is operated by Wise Ventures B.V., Oker 5, 8253 KS Dronten, the Netherlands, registered with the Dutch Chamber of Commerce (KvK) under number 92497101. You can reach us at [email protected].

2. Which Terms Apply to Your App

Modo is distributed in different ways, and the store you install it from adds its own terms on top of ours.

3. Who May Use Modo

You must be at least 13 years old to use Modo. If you are under 18, you may only use Modo with the permission of a parent or guardian. Most features need an account, and you agree to give accurate information when you create one.

4. Schools and Organisations

These terms are for individual learners. If you use Modo through your school or another organisation, that deployment runs under a separate agreement between us and that organisation, and where the two differ that agreement takes precedence. Schools and organisations may not use personal accounts to provide Modo to their students. For a school licence, contact [email protected].

5. Your Licence

We grant you a personal, non-exclusive, non-transferable right to use Modo for your own language learning, for as long as you comply with these terms. You may not copy, resell, sublicense or redistribute the app or its content, and you may not use it to build a competing product or to train machine learning models.

6. Your Account

You are responsible for keeping your login details safe and for activity under your account. Tell us promptly if you think someone else has access. Accounts are personal, so please do not share them.

7. Acceptable Use

You agree not to:

• Break, overload, probe or reverse-engineer the service, or bypass any limits or security measures
• Scrape or bulk-extract exercises, audio or other content
• Use the service unlawfully, or to infringe anyone else's rights
• Resell or commercially exploit access to Modo

8. Leaderboards and Your Name

Modo has XP leagues. A name and your XP are visible to the other learners in your league. The first time you open the leaderboard you choose whether to appear under the name you gave during onboarding or under a random anonymous name, so you can take part without being identifiable. Give your own name during onboarding rather than someone else's, and we may replace a name that impersonates another person or that is clearly offensive. We may also reset XP or league positions gained by cheating or by exploiting a bug.

9. Modo Pro Subscriptions

Modo is free to start. Modo Pro is a paid subscription, available as a monthly or an annual plan, that unlocks the more advanced topics and removes energy limits. The price, billing period and currency are always shown before you confirm your purchase.

Where you bought it decides who handles the payment:

• In the iOS and Android apps,Apple or Google processes the payment and each renewal. You manage and cancel the subscription in that store's account settings, and refund requests go to that store under its own refund policy.
• In the web app, you buy directly from Wise Ventures B.V. through our payment provider. You manage and cancel that subscription in your Modo account, and we handle refund requests ourselves.

If you start Modo Pro with a free trial from the App Store or Google Play, the trial turns into a paid subscription automatically at the end of the trial period unless you cancel before it ends. The store shows you the trial length and the price that follows before you confirm.

If we change the price of a subscription we will tell you in advance, and the new price applies only from the next billing period, so you can cancel before it takes effect.

10. Right of Withdrawal

As a consumer in the EU you normally have 14 days to withdraw from a distance purchase. Because Modo Pro gives you immediate access to digital content, you expressly ask us to start performance straight away and acknowledge that you lose your right of withdrawal once that access begins.

For purchases made in the iOS or Android app, refunds are handled by Apple or Google under their own refund policies, which may be more generous than this. For purchases made in the web app, email [email protected] and we will deal with your request directly.

11. Our Content and Your Feedback

The Spanish exercises, audio, text and software, and the Modo name and branding, belong to us or our licensors and stay that way. If you send us feedback or suggestions, you allow us to use them to improve Modo without any obligation to you.

12. Availability and Changes to the Service

We work hard to keep Modo available and its content accurate. We do not promise that the service will be uninterrupted or error-free: there will be maintenance, and occasionally downtime and bugs. We do not promise that Modo will get you to any particular level of Spanish, pass any exam, or produce any specific result — how much you learn depends on how you use it. Modo evolves, so we may add, change or remove features and content. If we remove a paid feature you are currently paying for, you can cancel, and where the store allows it we will refund the unused part of your current period.

13. Third-Party Stores and Services

Modo relies on third parties, including the app stores that distribute it and the providers listed in the privacy policy above. We are not responsible for their services or their terms.

14. Liability

We are liable for damage caused by our intent or gross negligence, and for anything that cannot be excluded or limited under Dutch law. Beyond that, our liability is limited to the amount you paid us in the twelve months before the event, and we are not liable for indirect or consequential loss. Nothing in these terms limits your mandatory rights as a consumer.

15. Suspension and Ending the Agreement

You can stop using Modo and delete your account at any time; see Deleting Your Modo Account or Your Data above. We may suspend or close an account that breaches these terms or that we are required to act on by law. Where reasonable we will warn you first, and if we close a paid account without cause we will refund the unused part of your current period.

16. Changes to These Terms

We may update these terms, for example when features or laws change. If a change matters to you, we will tell you in the app or by email before it takes effect. If you keep using Modo after that, the new terms apply. If you do not agree, you can stop using Modo and cancel your subscription.

17. Law and Disputes

Dutch law applies to these terms. That does not affect the mandatory consumer-protection rules of the country you live in, and as a consumer you can always bring a claim before the courts of your own country of residence. If something goes wrong, email us first at [email protected]— most things are quicker to sort out that way.

18. Other

If any clause turns out to be invalid, the rest stays in force. We may transfer our rights and obligations under these terms to another company, without reducing your rights. These terms and the privacy policy above form the whole agreement between us, and the English version prevails.