Shining Apps LLC - Cambridge English Apps

Privacy Policy and terms of Service

Terms of Service

Welcome to our website and apps. By accessing or using our services, you agree to be bound by these Terms of Service and our Privacy Policy. “Shining Apps LLC”, “we”, “us” or “our” refers to the owner and controller: Shining Apps LLC, 530-B Harkle Road, STE 100, Santa Fe, NM 87505, United States. “You” refers to the user of our services.

  • The content on this website/app is for general information and use. We may update it without prior notice.
  • We do not warrant that the information is accurate, complete, or suitable for a particular purpose. You acknowledge it may contain inaccuracies and we exclude liability to the fullest extent permitted by law.
  • Your use of any information or materials is at your own risk. It is your responsibility to ensure any products, services, or information meet your needs.
  • This website/app contains material owned by or licensed to us (including design, layout, look and graphics). Reproduction is prohibited other than in accordance with the applicable license or a prior written consent.
  • All trademarks not owned by us are acknowledged.
  • Unauthorised use may give rise to a claim for damages and/or be a criminal offence.
  • Links to third-party sites are provided for convenience only. We do not endorse and are not responsible for their content.
  • You may not create a link to this website from another site or document without our prior written consent.
  • These Terms are governed by the laws of Spain. If you access our services from another jurisdiction, you are responsible for compliance with local laws.

Privacy Policy

This Privacy Policy explains how Shining Apps LLC (“we”, “us”, “our”) collects and processes your personal data when you use our website and apps. We are committed to protecting your privacy and handling your data transparently and lawfully under the EU General Data Protection Regulation (GDPR).

Controller & EU Representative

Controller: Shining Apps LLC, 530-B Harkle Road, STE 100, Santa Fe, NM 87505, United States. Contact: info@shiningapps.com
Pursuant to Article 27 of the EU General Data Protection Regulation (GDPR), we have appointed the following representative in the European Union:
EU Representative (Art. 27 GDPR): Paula Klein, Balmes 241 4th Floor, 08006 Barcelona, Spain. Email: gdpr@tckrlabs.com

What Personal Data We Collect

We collect only the data necessary for the purposes described below. We do not collect Special Category Data.

  • Account & Profile (iOS/Android/Web): name, email, optional profile photo.
  • Auth Identifiers: IDs from Apple/Google sign-in (e.g., Apple identifier, Google UID).
  • Usage & Diagnostics: app events, crash logs, device information (model, OS version), and general analytics.
  • Support: messages you send us (e.g., via email or in-app support).
  • Cookies and similar technologies on the website (see “Cookies” section).

Purposes & Lawful Bases

We process your personal data for the following purposes and on the following lawful bases:

  • Provide and operate the services (create accounts, enable exercises, maintain subscriptions and entitlements) — Performance of a contract (Art. 6(1)(b)).
  • Customer support and communicationsPerformance of a contract and/or Legitimate interests (Art. 6(1)(b),(f)).
  • Analytics, service improvement, fraud prevention, and securityLegitimate interests (Art. 6(1)(f)); where required for cookies/SDKs, Consent (Art. 6(1)(a)).
  • Legal compliance (e.g., tax, accounting) — Legal obligation (Art. 6(1)(c)).

Recipients & Processors

We share personal data with trusted service providers acting as processors, strictly under data processing agreements. Typical categories include: hosting and infrastructure, authentication, analytics, payments, crash reporting, and messaging. Examples include (as applicable): Google/Firebase, Apple, Stripe, Google Play, cloud hosting providers, and email delivery providers. We do not sell your personal data.

Data Retention

We retain personal data only as long as necessary for the purposes above or as required by law:

  • Account data: retained for the duration of the account and, unless you exercise your right to erasure under Article 17 GDPR, for up to 6 years after closure to comply with legal obligations (e.g., tax and accounting).
  • Purchase and subscription records: up to 6 years for tax/accounting.
  • Support communications: up to 24 months after resolution.
  • Analytics and logs: typically 12–24 months, or as configured by the provider.

Your Rights

Subject to conditions and exceptions under GDPR, you have the right to request: access, rectification, erasure, restriction, data portability, and to object to processing based on legitimate interests. Where we rely on consent, you may withdraw it at any time. To exercise your rights, contact info@shiningapps.com or our EU Representative at gdpr@tckrlabs.com.

You also have the right to lodge a complaint with a Supervisory Authority, in particular in your habitual residence, place of work, or place of the alleged infringement.

Security

We implement administrative, technical, and organizational measures appropriate to the risk to protect personal data against unauthorized access, loss, or alteration. No system is 100% secure, but we strive to continuously improve our safeguards.

Marketing Communications

We send marketing emails only with your consent or as otherwise permitted by law. You can opt out at any time by using the unsubscribe link in an email or contacting us at info@shiningapps.com. Opting out will not affect essential service messages.

Cookies and Similar Technologies

We use cookies/SDKs to operate the site/app, remember preferences, analyze usage, and, with consent, for marketing. Non-essential cookies/SDKs are used only if you consent. You can change your preferences at any time via our cookie settings.

  • Strictly necessary: service operation and security (no consent required).
  • Analytics: understanding usage and improving the service (consent).

Children’s Data

Our services are not directed to children under 16. We do not knowingly collect personal data from children under 16. If you believe a child has provided personal data, please contact us to delete it.

Automated Decision-Making

We do not engage in automated decision-making, including profiling, that produces legal or similarly significant effects on you.

Contact

Controller contact: info@shiningapps.com
EU Representative: Paula Klein, Balmes 241 4th Floor, 08006 Barcelona, Spain. Email: gdpr@tckrlabs.com

Returns

For app store purchases, returns and refunds are handled according to the respective store’s policies (Apple App Store / Google Play). For purchases made directly from us, unless otherwise required by applicable law, lifetime licenses and in-term subscriptions are non-refundable. If you cancel a subscription, access continues until the end of the current billing period unless stated otherwise.