Privacy Policy

“Sproud” is a brand of Digital Literacy S.L.

Digital Literacy S.L. (“Digital Literacy”, the “Company”, or “we/us”) is committed to respecting and protecting the privacy of its users (“You”, or the “User”).

This Privacy Policy explains our practices regarding the use of personal data collected and processed through our service/app Sproud (the “Service”, or “App”).

This Privacy Policy integrates our conditions of use of our Service.

Summary

Digital Literacy processes personal data in relation to the Service as data controller (as defined under the EU General Data Protection Regulation (GDPR)).

In order to provide the Service, Digital Literacy relies on trusted third-party service providers acting as data processors or service providers on our behalf. These providers may process personal data strictly under our instructions and under contractual data protection obligations.

You are responsible for the content you choose to provide when using the Service, including messages, exercise responses, and information voluntarily entered into the App.

The Services are designed for use by individuals meeting the minimum legal age applicable in their jurisdiction (generally 16 years or older within the European Union), and we do not knowingly collect personal information directly from children below this age.

Both Digital Literacy and you agree to comply with this Privacy Policy.

A. Data Processed by Digital Literacy as Data Controller

1. Data Controller

The Data Controller is:

Digital Literacy S.L.
Roger de Flor 193, bajos
08013 Barcelona, Spain

You can contact us by email at: legal@sproud.app

2. Data Collection by the Company Through the Services

Digital Literacy collects and processes the following personal data through the Service.

Registration Data

When registering through Apple Sign In, we receive your Apple account identifier and, if you choose to share it, your email address.

Additionally, we collect the username or display name that you choose inside the App.

If required data is not provided, an account cannot be created.

Usage and Interaction Data

When you use Sproud, we may process app interaction events, session usage data, and feature interaction data.

Conversation and User Content Data

When you interact with Sproud, we process messages and conversation content, responses to exercises and guided activities, and check-ins or self-reported inputs.

This data is used to provide continuity of the Service and personalize the user experience.

Wellbeing Interaction Data

As part of providing the Service, we may process information related to themes you choose to explore, such as fears or challenges, behavioral or coping patterns discussed during exercises, and progress across exercises, rituals, or sessions.

This information is processed only to provide and improve the Service experience.

AI Interaction Processing

Sproud uses artificial intelligence technologies to generate responses and provide interactive experiences.

User inputs may be processed by AI service providers acting on our behalf under contractual data protection obligations.

We may use anonymized or aggregated interaction data to improve our services. We do not use identifiable personal conversations to train external AI models.

Payments Data

Payments are processed by Apple through Apple In-App Purchases.

Payment providers process payment data according to their own privacy policies. Digital Literacy does not collect or store payment card data.

Device and Technical Information

We may collect technical data such as IP address, device type, operating system, app version, and diagnostic or crash data.

This information is used to improve service quality and security.

Exercise and Assessment Data

When you complete exercises or questionnaires in the App, we process your responses to provide the Service and improve user experience.

Information Collected, Purpose, and Legal Basis

We collect personal data for the purposes described below under the following legal bases.

Registration Data
Purpose: Providing the Service, account management, customer support, and service communications.
Legal Basis: Performance of the contract.

Registration Data (Marketing Communications)
Purpose: Sending communications about the Service, updates, and new features.
Legal Basis: Consent.

Usage Data
Purpose: Providing, maintaining, and improving the Service.
Legal Basis: Performance of the contract.

Conversation Data
Purpose: Generating AI responses, maintaining conversation continuity, and providing personalized experiences.
Legal Basis: Performance of the contract.

Device and Technical Data
Purpose: Ensuring security, stability, and performance of the Service.
Legal Basis: Legitimate interest.

Exercise and Assessment Data
Purpose: Personalization of the Service and improvement of user experience.
Legal Basis: Performance of the contract and, where applicable, consent.

Data Sources

We obtain personal data directly from you and indirectly through your use of the Service.

Consent

Where we rely on consent, you may withdraw consent at any time by contacting us.

Service Optimisation

We may process anonymized and aggregated information to improve or promote our services.

Disclosure

We may disclose information to comply with legal obligations, to provide the Service, in case of company sale or change of control, or to service providers acting on our behalf.

Data Retention

We retain personal data for the duration of your account and subscription and for a limited period thereafter where required for legal or administrative purposes.

3. International Transfers of Data

Some service providers may process data outside the European Economic Area.

Where this occurs, we implement appropriate safeguards such as Standard Contractual Clauses.

4. Data Security

We implement technical and organizational measures designed to protect personal data from unauthorized access, loss, misuse, or alteration.

In case of a security breach, we will notify affected users where required by law.

5. Data Subject Rights

You have the right to access your personal data, correct inaccurate data, request erasure, object to processing, restrict processing, request data portability, withdraw consent, and file a complaint with the Spanish Data Protection Authority (AEPD).

To exercise your rights, contact: legal@sproud.app

6. Commercial Communications

Where you provide consent, you may receive communications about Sproud or Digital Literacy services.

You may unsubscribe at any time.

7. General

We may update this Privacy Policy to reflect legal or regulatory developments.

Unless mandatory local law states otherwise, this Privacy Policy is governed by Spanish law.