HEYHOLA · REAL SPANISH FOR REAL LIFE

Privacy Policy

Effective Date: October 18, 2026

Last Updated: October 18, 2026

HeyHola is developed and operated by Frankly, LLC ("Frankly," "we," "our," or "us").

This Privacy Policy explains how information is handled when you visit our website at heyhola.app, use the HeyHola mobile application, or communicate with us.

At Frankly, we believe learning a language shouldn't require giving up your privacy.

HeyHola is being built around a simple principle: Your learning experience should belong to you.

Our privacy approach

HeyHola is designed with privacy in mind.

Our goal is to provide a Spanish-learning experience that operates primarily on your device, without requiring unnecessary accounts, tracking, or cloud processing.

Our privacy principles include:

• Local-first learning: Learning progress, preferences, and other app information are designed to be stored on your device.
• Planned on-device intelligence: Local AI processing is a planned capability. Generative AI, speech recognition, and pronunciation scoring are not currently active.
• Offline functionality: Core learning features are designed to work without an internet connection.
• No advertising-based tracking: We do not intend to monetize your learning activity through behavioral advertising.
• Data minimization: We aim to collect only the information necessary to operate and improve our services.

Certain optional features, purchases, communications, or website functionality may require information to be processed outside your device.

Information we handle

The information we handle depends on how you interact with HeyHola.

Information stored in the app

HeyHola stores learning progress, preferences, and authored practice content locally on your device. Local information includes:

• Learning progress and completed lessons.
• Vocabulary and phrases you've practiced.
• Learning preferences and selected interests.
• Practice history and performance.
• Personalization settings.
• Other information you voluntarily enter into the application.

Learning information is processed locally. System backups, device transfers, and exports you choose to make can create copies outside the app, as described below.

Website information

When you visit heyhola.app, certain technical information may be processed to deliver the website, maintain security, and diagnose technical problems.

Depending on our hosting configuration, this may include:

• IP address.
• Browser type.
• Device type.
• Pages requested.
• Date and time of access.
• Basic technical and security logs.

Vercel hosts our website and processes normal hosting and security logs, which may include the technical information listed above.

We do not use this information to create advertising profiles.

Launch updates

Our launch-update integration uses Resend to manage subscribers in the HeyHola Launch Updates list. Signup is currently inactive until the production API key is configured. When signup is activated, your email address will be sent through our website to Resend only if you choose to subscribe.

We use this information to communicate about HeyHola, including launch announcements, product availability, and relevant updates.

You can unsubscribe at any time using the instructions included in our emails or by contacting us.

We do not sell or rent our email subscriber lists.

Support communications

If you contact us for assistance, we may collect:

• Your email address.
• Information you provide in your message.
• Relevant device or application details you voluntarily share.

We use this information to respond to your request and provide support.

How we use information

We use information only for legitimate operational purposes, including:

• Providing and maintaining HeyHola.
• Supporting website functionality and security.
• Delivering requested launch updates.
• Responding to support inquiries.
• Processing purchases through authorized app stores.
• Diagnosing technical issues.
• Meeting applicable legal obligations.

We do not sell your personal information.

We do not use your learning activity for targeted advertising.

On-device intelligence

On-device AI is a planned capability, not an active feature. Current practice uses authored content. Generative AI, speech recognition, and automated pronunciation scoring are not currently active, and the current app has no external AI processing integration.

Future local AI would prioritize processing on your device. Availability, device requirements, and data handling will depend on the feature actually released. We will explain any new data flows before introducing functionality that sends learning information to external AI services.

Storage and security

HeyHola is designed to store learning information locally on your device.

We use reasonable technical and organizational measures appropriate to the information we process.

However, no device, software application, or method of electronic storage is completely secure.

Android cloud backups are disabled in the app configuration, although device-to-device transfers may still occur depending on the device and operating system. On iOS, application data may be included in device or iCloud backups according to your settings. Local storage does not mean that operating-system backups are excluded.

You can manually export learning information and choose where to save or share the file. Copies you export are subject to the privacy and security practices of the destination you select.

You are responsible for maintaining appropriate security protections on your device.

Third-party providers

HeyHola may rely on third-party providers for limited operational purposes.

These may include:

Apple App Store and Google Play

If you download HeyHola or make purchases through an app store, Apple or Google may process information according to their own privacy policies.

Website Hosting

Vercel processes website requests and normal hosting and security logs.

Email Communications

Resend is the provider configured for launch-update subscriber management. The signup integration remains inactive until the production API key is configured. Email and support providers may process messages you choose to send us.

We do not authorize these providers to use your information for behavioral advertising on our behalf.

Each provider may operate under its own privacy policy and applicable contractual obligations.

Cookies and tracking technologies

We aim to minimize the use of cookies and tracking technologies.

The current website and app contain no advertising trackers or third-party analytics SDKs, including Google Analytics or Vercel Analytics. This does not exclude normal Vercel hosting and security logs or telemetry from development tools used to build the app.

Certain essential technologies may be used to support website functionality, security, or preferences.

If we introduce optional analytics or nonessential tracking technologies, we will update this policy and provide appropriate choices where required by law.

Data retention

Information stored locally within the HeyHola application generally remains on your device until you delete it, reset the application, or remove the application.

Deleting the application may remove locally stored learning data, subject to your device's backup and restoration settings.

When signup is activated, subscriber records will be managed in Resend. We have not configured automatic contact expiration or a fixed deletion period. Unsubscribing stops future marketing messages but does not automatically delete the contact record. You may request deletion by contacting support@heyhola.app; limited information may need to be retained for suppression, legal, or operational purposes.

Support communications and technical logs are retained only as long as reasonably necessary for their intended purposes or applicable legal requirements.

Your choices and rights

You have control over several aspects of your information.

Depending on how you use HeyHola, you may:

• Manage or delete locally stored application information through available app features.
• Uninstall HeyHola from your device.
• Unsubscribe from marketing communications.
• Request access to or deletion of personal information we maintain about you.
• Contact us with questions about our privacy practices.

Please understand that we cannot access or delete information stored exclusively on your device.

For information we maintain through our website, email services, or support systems, we will respond to applicable privacy requests in accordance with relevant laws.

Children’s privacy

HeyHola is intended for people ages 13 and older and is not intended for children under 13. We do not knowingly collect personal information from children under 13 through the Services. If we learn that we have collected such information, we will take appropriate steps to delete it.

A parent or guardian who believes a child under 13 has provided personal information to us can contact support@heyhola.app. Users under the age of majority should use HeyHola with a parent or guardian’s permission.

International users

HeyHola may be accessed from locations outside the United States.

Information processed through our website, email communications, or support services may be transferred to or processed in the United States or other countries where our service providers operate.

Where required, we will implement appropriate safeguards for international data transfers.

Users in certain jurisdictions may have additional rights concerning access, correction, deletion, portability, or restrictions on the processing of personal information.

You may contact us to exercise applicable rights.

Changes to this policy

We may update this Privacy Policy as HeyHola develops or as legal and operational requirements change.

When we make changes, we will update the "Last Updated" date at the top of this page.

If changes materially affect how we handle personal information, we will provide additional notice where required by law.

Contact us

If you have questions about this Privacy Policy, your personal information, or our privacy practices, please contact:

Frankly, LLC

Developer of HeyHola

Website: heyhola.app

Email: support@heyhola.app