Privacy Policy

1. Data controller

The controller of your data is Verbio Academy, operator of the Verbio service (verbioacademy.com).

2. What data we process

• Account data: email address, display name, hashed password.
• Training data: test results, statistics, streak, answer choices.
• Technical data: IP address, device identifier, browser data, error logs.
• Correspondence: content of messages sent to support.

3. Purposes and legal bases

• Providing the service and managing your account — performance of contract (Art. 6(1)(b) GDPR).
• Invoicing, payment and refund handling — legal obligation and performance of contract.
• Security and abuse prevention — legitimate interest.
• Customer support and transactional communication — performance of contract.
• Product improvement (aggregated analysis) — legitimate interest.

4. Who we share data with

• Paddle.com Market Limited — Merchant of Record: handles sales, payments, taxes, invoicing and refunds.
• Infrastructure providers (hosting, database, transactional email) — as processors.
• Public authorities — only when required by law.

5. Transfers outside the EEA

Some of our processors may handle data outside the EEA. In that case we use the Standard Contractual Clauses approved by the European Commission.

6. Retention period

We keep account data while the account is active and for 30 days after deletion. Billing data — 5 years (tax obligation).

7. Your rights

You have the right to: access, rectification, erasure, restriction, portability, objection, withdrawal of consent and to lodge a complaint with your supervisory authority.

8. Security

We use transport encryption (HTTPS/TLS), hashed passwords and row-level access control in the database.

9. Cookies

We use only cookies strictly necessary for the Service (login session). We do not use marketing or tracking cookies.

10. Contact

For data-related questions: support@verbioacademy.com