Privacy Policy

1. Data controller and contact

The operator identifies the trading name as Puentes en Español and the controller/operator as Federico Hung, a self-employed individual in Spain. Declared address: Roda 8, Valencia, Spain; full postal address and postcode remain unverified. Contact for legal, privacy, and support requests: Puentes institutional email federico@puentes.one; phone for Federico +34678373107. Confirm this identity and address, the controller/processor roles, and the legal notice requirements, including whether the supplied NIT satisfies Spanish identification rules.

2. Data processed

Depending on use, the platform may process account email and authentication IDs; profile and role; lesson, class, booking, attendance, and progress records; Talk sessions, access, and credit usage; text exchanged with AI tutors; optional Talk evidence and summaries; payment references; and support or privacy requests. Verify exact fields against production before approval.

3. Purposes and legal bases

Account access, requested lessons, bookings, Talk sessions, entitlements, and payment administration support the requested service and user relationship. Accounting, security, fraud prevention, and legal requests may rely on applicable legal obligations or other lawful grounds. Optional persistent Talk memory is distinct from temporary processing needed for a live conversation and is intended to require explicit opt-in. The operator must validate the ground for each purpose and jurisdiction; this notice does not assume that all processing requires consent.

4. Registration and Magic Link

Student sign-in uses one-time email links through Supabase Auth. Email and authentication data send and validate links, secure accounts, and maintain sessions. The mail delivery provider used by Supabase Auth is not identified in the reviewed application code.

5. Academy and learning progress

Academy may process lesson activity, answers, attempts, feedback, assessment events, class participation, and progress to provide the curriculum experience. Academy records are separate from Talk evidence; Talk observations do not automatically change Academy progress or assessment.

6. Talk voice and AI conversations

Talk uses WebRTC to send live audio to the server-selected real-time provider for speech processing and response generation. OpenAI and Alibaba Cloud/DashScope Qwen are code integrations; the provider selected depends on server configuration. The reviewed Puentes code did not reveal complete raw-audio recording to Puentes storage, but this does not establish provider-side retention. Provider settings, contracts, retention, and processing regions must be checked.

7. Transcripts and optional Talk memory

Temporary transcript events may be used to operate a live conversation. Persistent pedagogical memory is optional and is not needed for ordinary Talk use. Without valid opt-in and pilot authorization, the server must not capture evaluation samples or create new persistent memories. For an authorized consented pilot, the implementation can keep a representative sample capped at 12 exchange pairs and 6,000 characters. It does not store complete audio or a complete permanent transcript by default.

The sample is intended to expire within 24 hours and is cleared after processing or by scheduled cleanup. A delayed or failed worker/cron can delay deletion, so 24 hours is an operational target, not an absolute guarantee. The configured text evaluator receives the sample only after server checks for eligibility, consent, sufficient evidence, budget, and idempotency; that provider may differ from the voice provider.

8. Pedagogical analysis

Post-session analysis may produce a summary, supported strengths, recurring language difficulties, self-corrections, practiced vocabulary, and suggestions. It does not assess phonetics from text alone or infer CEFR or lasting mastery from one observation. Proposed findings are distinct from validated memory; only evidence meeting application validation rules may personalize future Talk context.

9. Retention and deletion

The reviewed code does not define one approved retention period for account, class, progress, session, credit, purchase, and accounting records. The operator must publish a schedule by data category. Talk samples target expiry within 24 hours; pedagogical events and profile summaries may persist in existing Talk tables without a complete code-defined schedule.

The profile can record a Talk-memory deletion request and stop pending optional processing, but does not confirm stored memory has been erased; staff handling is required. Supabase backup retention was not verified and copies may remain until overwritten or expired under its schedule. A request is not immediate deletion from backups.

10. Providers and recipients

Code integrations include Supabase for Auth/PostgreSQL; Vercel for hosting/server functions; OpenAI and Alibaba Cloud/DashScope Qwen for selected realtime voice and/or configured text evaluation; Daily for human live-class video; and Stripe for credit checkout/payment webhooks. This does not prove each provider receives every data category or is enabled in every environment. Verify production settings, provider entities, subprocessors, regions, retention terms, and data-processing agreements. Supabase Auth mail delivery also needs confirmation.

11. International transfers

Providers may process data in different countries. Production regions, destinations, transfer mechanisms, and safeguards were not verified in the repository. Before publication, map transfers and document applicable contractual clauses, adequacy decisions, or other lawful safeguards. This notice does not claim that all transfers are covered.

12. Payments

Stripe Checkout and payment webhooks are integrated. Puentes stores payment references and credit-ledger information to grant and reconcile access. Confirm the production flow, tax records, card-data roles, and retention periods.

13. Cookies and similar technologies

The reviewed code uses authentication/session cookies and a short-lived calendar authorization-state cookie. No analytics or advertising tags were found in inspected source, but production has not had a complete browser scan. Verify the cookie inventory and provide consent for non-essential technologies where required before enabling them.

14. Security

Protected operations use authenticated server routes and data-access controls. No system can guarantee absolute security. The operator must verify and document access controls, incident response, backups, vendor review, and breach-notification procedures.

15. Privacy rights and requests

Depending on applicable law, people may have rights to access, correct, delete, restrict, object, receive a copy, or complain to a regulator, subject to conditions and exceptions. A dedicated privacy contact is pending. The current profile flow can turn off Talk memory and record a deletion request; other access, correction, account deletion, and portability requests need a published support process, identity checks, response timelines, and regulator details.

16. Withdrawing optional consent

Turn off Talk memory in Profile → Privacy and memory. This stops new optional capture and should stop pending optional work where possible. It does not undo completed lawful processing or erase stored memory automatically; a separate deletion request may be needed.

17. Children and age eligibility

The reviewed application has no age gate or guardian-consent flow. The operator must decide and publish minimum age, whether the service is directed to children, and safeguards before launch. Until then, do not represent the service as designed or approved for children.

18. Changes and privacy contact

The operator should version this notice, state its effective date, and provide renewed information or consent when a material change requires it. Editorial changes that do not alter purposes or rights should not automatically trigger new consent. Contact: Puentes institutional email federico@puentes.one; phone for Federico +34678373107. The full postal address and postcode remain unverified. Tax identifier supplied by the operator (NIT): z0601325h. Qualified Spanish counsel should confirm whether this identifier meets Spanish legal-notice requirements.