1. General Information

At Ogima, we are committed to protecting your personal data and respecting your privacy. This Privacy Policy explains how we collect, use, store, and share your personal data when you use our website, mobile application, and related services ("Service").

This Privacy Policy complies with the General Data Protection Regulation (Regulation (EU) 2016/679 – "GDPR") and applicable German data protection laws.

By using our Service, you agree to the terms of this Privacy Policy. If you do not agree, please refrain from using our Service.

2. Data We Collect

a. Account Registration

To create an Ogima account, we collect your email address and age. Depending on your location, we may also collect your phone number.

If you choose to register using a social media account (e.g., Google or Facebook), we receive personal data from that provider (e.g., your email and contact list) based on your settings with them. You can manage this in your Ogima profile.

b. Profile Information & User-Generated Content

We create a profile page ("Profile") upon registration. It may include a username, profile picture, and optional bio. By default, profiles are public, but you can change this in settings.

Your learning progress, achievements, and social interactions may be publicly visible unless you change visibility settings. You may submit user-generated content (UGC) such as comments and posts. Ogima may moderate or remove UGC that violates our Community Guidelines.

c. AI & Automated Features

Ogima provides AI-powered features like conversation simulations and feedback. We may process your interactions using third-party AI providers (e.g., OpenAI). These services may involve limited profiling, but we do not engage in automated decision-making that produces legal or similarly significant effects (Article 22 GDPR). You should avoid submitting sensitive personal data during interactions with AI tools.

d. Speech Recognition & Audio Processing

Some learning activities require speech input. Your voice data may be processed using external services (e.g., Google, Apple, AWS). You may opt out of voice processing in your settings.

e. Contact Syncing

If enabled, Contact Sync lets us identify users you may know. Raw contact data is not stored—only non-reversible hashed representations.

f. Usage Data & IP Address

We collect technical and behavioral data including device/browser details, log files, and IP address for fraud prevention, diagnostics, and security. IP addresses are retained for up to 30 days.

g. Cookies & Tracking Technologies

We use cookies and similar technologies for functionality, analytics, and personalized services. You can manage your preferences via our Privacy Preference Center. For EU users, non-essential cookies are disabled by default in accordance with Article 5(3) of the ePrivacy Directive and EDPB Guidelines 02/2023.

h. Analytics & Performance Monitoring

We use tools like Google Analytics to assess platform usage. You may opt out via browser add-ons or our cookie settings.

3. How We Use Your Information

Ogima processes your data based on the following lawful bases under Article 6 GDPR:

• Contractual necessity – to provide our services.
• Legitimate interest – to improve the platform and ensure security.
• Legal compliance – to meet regulatory obligations.
• Consent – for personalized advertising and optional features.

a. Service Provision & Improvement

We use your data to deliver personalized learning, track progress, and improve functionality.

b. Communication & Notifications

We send essential updates, reminders, and promotions. You can manage your preferences in your account settings.

c. Compliance & Legal Obligations

We may share data to comply with legal obligations or defend against legal claims.

d. Personalized Advertising

With your explicit consent, we may share minimal data with advertising partners. EU and EEA users are opted out by default from personalized ads.

4. Data Sharing & Joint Controllership

We share data with third parties such as cloud providers, analytics vendors, and authentication partners. Where we jointly determine purposes and means of processing (e.g., with social login or advertising partners), we may act as joint controllers under Article 26 GDPR.

You will be informed of any such arrangements in the relevant user interface or consent mechanism. These partners are bound by contractual safeguards.

5. International Data Transfers

Where data is transferred outside the European Economic Area (EEA), we use lawful transfer mechanisms, such as:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Binding Corporate Rules (BCRs)

Transfer Impact Assessments (TIAs) are conducted where required, in line with EDPB Recommendations 01/2020

6. Your Rights Under GDPR

As an EEA resident, you have the following rights:

• Right of access – Obtain a copy of your data (Art. 15)
• Right to rectification – Correct inaccurate data (Art. 16)
• Right to erasure – Request deletion ("right to be forgotten") (Art. 17)
• Right to restrict processing (Art. 18)
• Right to object to certain processing, including profiling (Art. 21)
• Right to data portability (Art. 20)
• Right to withdraw consent at any time (Art. 7(3))
• Right to lodge a complaint with a supervisory authority (Art. 77)

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

7. Data Retention

We retain your data for as long as needed to provide services and fulfill legal obligations. You can delete your account at any time. Anonymized data may be retained for statistical analysis.

8. Children's Privacy

Ogima is intended for users aged 13+ (or the age of digital consent in your country). We do not knowingly collect data from children without verifiable parental consent. Parents may request deletion by contacting us.

9. External Links & Third Parties

We may link to third-party services not controlled by Ogima. Their data practices are governed by their own privacy policies. Please review those policies before engaging.

10. Updates to This Privacy Policy

We may periodically update this policy. If material changes are made, users will be notified via email or in-app. The "Last Updated" date reflects the latest version.

11. Contact & Data Protection Officer

If you have questions or concerns regarding this policy, please contact our Data Protection Officer:

Bengi Coskun
OGIMA GmbH
Winterfeldtstraße 21,
10781 Berlin, Germany
Email: support (you-know-which-symbol) ogimalearn.com

For unresolved issues, you may contact your local Data Protection Authority (DPA).