Privacy Policy

This Privacy Policy describes how Holingo ("we," "us," "our," or the "Company") collects, uses, stores, shares, and protects your personal information when you access or use the Holingo application and services (collectively, the "Service"). We are committed to protecting your privacy and handling your data with transparency, care, and respect for your rights. This policy applies to all users of the Service regardless of how they access it (web browser, mobile browser, or any future native application). By creating an account or using the Service, you agree to the collection and use of your information as described in this Privacy Policy. If you do not agree with any part of this Policy, please discontinue use of the Service. This Privacy Policy is incorporated by reference into our Terms of Service. Defined terms used but not defined here have the meanings given to them in the Terms of Service.

We collect information in the following categories: A. Account and Registration Information When you create an account, we collect: your first name, last name, email address, gender, date of birth, and optionally a profile photo (stored as an image file). This information is required to operate your account and provide personalized features. B. Authentication Data We generate and temporarily store one-time passcodes (OTPs) sent to your email for passwordless authentication. These codes are single-use, expire within 10 minutes, and are never stored permanently after use. We do not store passwords of any kind. C. Session Data We use passwordless, JSON Web Token (JWT) authentication. When you log in, we store signed access and refresh tokens in your browser's localStorage to keep you signed in; these tokens do not contain your password and can be invalidated by logging out. D. Learning and Progress Data We collect detailed information about your use of the learning features, including: modules started and completed, quiz question responses, quiz scores and answer histories, XP (experience points) earned and spent, daily streak counts and streak freeze usage, heart (life) counts, lesson completion timestamps, trophies and achievements unlocked, level progression, spaced repetition (SRS) review schedules, review difficulty ratings, and reading plan enrollment and daily progress. E. Social and Interaction Data We collect data about your social interactions within the Service, including: friend relationships (email addresses used to initiate requests and friend connection records), challenge records (initiator, recipient, XP totals, timestamps, outcomes), leaderboard rank data, and invitations (the email address you invite is stored with the invitation status until the invitation is accepted, declined or expires after 30 days, so we can track delivery and let the invited person respond). F. Communication Preferences We store your notification preferences including whether you have enabled or disabled: streak reminder emails, achievement notification emails, friend activity emails, push notification subscriptions, and other optional communication types. G. Push Notification Subscription Data If you enable push notifications, we store your browser or device push notification endpoint URL, public key (p256dh), and authentication secret (auth token) as provided by your browser's Web Push API. This data is used exclusively to deliver push notifications to your device. H. Device and Technical Data We automatically collect certain technical information when you use the Service, including: IP address (at time of request), browser type and version, operating system, device type, referring URLs, pages viewed, time spent on pages, and timestamps of interactions. This data is used for security monitoring, abuse prevention, and service improvement. I. Geolocation Data (Registration Only) At the time of account registration, we use your IP address to make a single request to a third-party geolocation service (ip-api.com) to determine your approximate country. This country information is stored with your profile for display purposes (e.g., leaderboard country flags). We do not continuously track your location and do not collect precise GPS data. J. Bible Reading Preferences We store your Bible language preference (KJV/English, French, or Spanish) locally in your browser's localStorage. This preference is not associated with your account on the server and is cleared if you clear your browser data. K. Dark Mode and UI Preferences Your dark mode preference is stored both locally (localStorage) and synced to your account in the database upon login. Other UI preferences (e.g., sound settings) may be stored in localStorage only.

We use the information we collect for the following purposes: A. Providing and Operating the Service To create and maintain your account, authenticate your identity via OTP, deliver personalized learning modules and content, calculate and display your XP, streaks, hearts, levels, and achievements, show your progress across modules and reading plans, power the spaced repetition review system, and enable social features including friends, challenges, and the leaderboard. B. Gamification and Personalization To track your daily activity for streak management, automatically apply streak freezes when you miss a day (if purchased), adjust quiz difficulty based on your performance history, schedule SRS reviews at optimal intervals, and deliver personalized reading plan reminders. C. Communications To send OTP authentication codes (required), send streak reminder and achievement notifications (if enabled), deliver challenge invitations and results from friends, send push notifications (if enabled), and send important account and Service updates. D. AI-Powered Quiz Generation To generate quiz questions by sending biblical chapter text (not personal data) to our AI provider. See Section 5 for full details. E. Security and Fraud Prevention To verify your identity, detect and prevent unauthorized access, monitor for abuse or violations of our Terms of Service, and protect the integrity of the Service. F. Analytics and Service Improvement To understand how users engage with the Service, identify features that need improvement, monitor error rates and performance, and develop new features. G. Legal Compliance To comply with applicable laws, respond to lawful requests from government authorities, enforce our Terms of Service, and protect our legal rights and the rights of others.

If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, we process your personal data under the following legal bases: Contractual Necessity (Article 6(1)(b) GDPR): Processing your name, email, authentication data, and learning progress is necessary to provide the Service you have requested and agreed to receive. Legitimate Interests (Article 6(1)(f) GDPR): We process technical data, security logs, and aggregate analytics data based on our legitimate interest in operating, securing, and improving the Service, provided these interests are not overridden by your rights. Consent (Article 6(1)(a) GDPR): We rely on your consent for: optional marketing or notification emails, push notification subscriptions, and geolocation-based country detection at registration. You may withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal. Legal Obligation (Article 6(1)(c) GDPR): We may process data as necessary to comply with applicable laws and respond to lawful government requests. You have the right to object to processing based on legitimate interests by contacting us at support@holingo.org.

Holingo uses the DeepSeek AI model to generate quiz questions, fill-in-the-blank exercises, and other learning content. Here is exactly what data is involved: What is sent to the AI: When you begin a learning module, the text of the relevant Bible chapter is sent to DeepSeek's API to generate quiz questions. No personal information — including your name, email, account ID, or any other identifying data — is included in these API requests. Caching: AI-generated questions are cached in our database after the first generation for each chapter, to minimize repeated API calls and ensure consistent question quality. Cached questions may include a sanitization pass (e.g., ensuring all answer options are populated) before delivery. AI Provider's Practices: DeepSeek AI processes the biblical text it receives according to its own privacy policy and data processing terms. We have selected DeepSeek based on our evaluation of its practices, but we cannot guarantee how DeepSeek handles data beyond our contractual arrangements. No Personal Data in AI Requests: We design our AI integration to explicitly exclude personal data from all requests. If you discover or suspect that personal data was inadvertently transmitted to an AI service, please notify us immediately at support@holingo.org. Accuracy Disclaimer: AI-generated content may contain theological inaccuracies or errors. See Section 9 of our Terms of Service.

We use the following types of storage technologies: Authentication: When you log in, we store signed access and refresh tokens (JWTs) in your browser's localStorage to keep you signed in. All traffic is transmitted over HTTPS in production. Browser localStorage: We use your browser's localStorage to store: your Bible language preference (KJV, French, or Spanish), your dark mode setting (synced to your account on login), and sound settings. This data is stored entirely on your device and is not transmitted to our servers except where noted. No Third-Party Tracking Cookies: We do not use third-party advertising, analytics, or tracking cookies. We do not place cookies from advertising networks, social media platforms, or third-party analytics services. Managing Cookies: You can configure your browser to refuse all cookies or to alert you when cookies are being sent. Clearing localStorage will reset your local preferences and log you out of the Service.

If you choose to enable push notifications through your browser or device, we store the following data on our servers: the push endpoint URL (provided by your browser), the p256dh public key, and the auth token — all of which are required by the Web Push protocol (RFC 8030) to deliver notifications securely. We use this data solely to send you push notifications for: daily streak reminders, achievement unlocks, challenge invitations and results, and reading plan reminders. We do not use push notification tokens for any other purpose. We do not share these tokens with third parties except as needed to route notifications through standard Web Push infrastructure (e.g., browser vendor push services such as those provided by Google or Mozilla, which handle delivery based on the endpoint URL). You can revoke push notification permissions at any time through your browser or device settings, or through the Settings page in the app. Revocation prevents future notifications and we will delete your stored push tokens upon detection or upon your request.

We send the following categories of email: Transactional (Required): Authentication OTP codes — necessary for login and cannot be opted out of while your account is active. Account security alerts (e.g., suspicious login attempts). Important policy updates or legal notices. Operational (Optional, enabled/disabled via Settings): Daily streak reminder emails. Achievement and level-up notifications. Friend request notifications. Challenge invitations and results. Reading plan daily reminders. We do not send promotional emails, advertisements, or marketing messages from third-party sponsors. We do not sell your email address or allow third parties to use it for their own marketing. If you try the 1-minute lesson on our website, we store your email address as a lead so we can pre-fill sign-up; we never send marketing emails to leads. To send emails, we use an email delivery service. Your email address is transmitted to this service only for the purpose of delivering the messages described above. To unsubscribe from optional emails, visit Settings > Notifications within the app, or use the unsubscribe link found at the bottom of each optional email.

We do not sell, rent, or trade your personal information to any third party. We share data only in the following limited circumstances: With Other Users (Limited): Your public username, XP total, level, and streak count are visible to other registered users through the leaderboard. The leaderboard shows only your public username, never your real name, email address, or profile photo. Your real name is shown only to friends you have accepted, and to a challenge opponent during the challenge. If you participate in a challenge, your opponent can see your XP progress during the challenge period. You may review and adjust your profile information and public username through the Settings page. With Service Providers: We share data with third-party service providers who help us operate the Service, including: our AI provider (DeepSeek) — receives Bible text only, not personal data; our email delivery provider — receives your email address to deliver messages; and our geolocation provider (ip-api.com) — receives your IP address at registration only. These providers are contractually bound to use data only for the services they provide to us. For Legal Compliance: We may disclose your information if required to do so by law, regulation, court order, or government request, or to protect the rights, property, or safety of Holingo, our users, or the public. Business Transfers: If Holingo undergoes a merger, acquisition, bankruptcy, or sale of assets, your information may be transferred as part of that transaction. We will notify users via email or in-app notice before any such transfer takes effect, and the acquiring party will be required to honor the terms of this Privacy Policy. Aggregated or Anonymized Data: We may share aggregated, de-identified statistical data (e.g., total number of modules completed, average XP per day) that cannot reasonably be used to identify individuals.

We retain your personal information for as long as your account is active and for a reasonable period thereafter to fulfill the purposes described in this Policy. Active Accounts: We retain all account data (profile, progress, social, preferences) for the duration that your account is active. Account Deletion: When you delete your account through Settings, we immediately delete your personal data. Certain data categories may be retained beyond this period: - Anonymized, aggregated statistical data (e.g., total XP for leaderboard history calculations) may be retained indefinitely as it cannot identify you. - Server-side logs containing your IP address may be retained for up to 90 days for security and abuse prevention purposes. - Data we are required to retain by law (e.g., transaction logs, fraud records) may be kept for the legally required retention period. - If a legal dispute or investigation is pending at the time of deletion, we may retain relevant data until the matter is resolved. AI-Cached Content: Quiz question caches stored in our database are associated with Bible chapters, not individual users, and are retained independently of account lifecycle. Authentication OTPs: OTP codes are deleted immediately upon use or expiration (10 minutes). Push Notification Tokens: Deleted upon account deletion or upon revocation of push notification permission.

Depending on your location, you may have the following rights with respect to your personal data: Right of Access: You have the right to request a copy of the personal data we hold about you. Contact us at support@holingo.org with the subject "Data Access Request." Right to Rectification: You can update your name and profile information directly through the Settings page. For other corrections, contact us. Right to Erasure (Right to Be Forgotten): You may request deletion of your account and associated personal data at any time through Settings > Account > Delete Account. You may also submit a deletion request to support@holingo.org with the subject "Account Deletion Request." Right to Restriction of Processing: You may request that we restrict processing of your data in certain circumstances (e.g., while we investigate an accuracy dispute). Right to Data Portability: You may request a machine-readable export of your personal data. Contact us at support@holingo.org with the subject "Data Portability Request." Right to Object: You may object to processing of your data based on legitimate interests (see Section 4). To opt out of optional email notifications, use the Settings page or unsubscribe link. Right to Withdraw Consent: Where we process data based on your consent (e.g., push notifications, optional emails), you may withdraw that consent at any time without affecting the lawfulness of prior processing. Right to Lodge a Complaint: If you are in the EEA or UK, you have the right to lodge a complaint with your local data protection supervisory authority if you believe we have violated your privacy rights. We will respond to all legitimate privacy rights requests within 30 days. In some cases, we may need to verify your identity before fulfilling a request.

If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA): Right to Know: You have the right to request disclosure of the categories and specific pieces of personal information we have collected about you, the categories of sources, the business purposes for collection, and the categories of third parties with whom we share it. Right to Delete: You have the right to request deletion of your personal information, subject to certain exceptions (e.g., legal compliance, fraud prevention). Right to Correct: You have the right to request correction of inaccurate personal information. Right to Opt-Out of Sale or Sharing: We do not sell or share your personal information with third parties for cross-context behavioral advertising. You do not need to take any action to opt out, as we do not engage in these activities. Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA/CPRA rights. To exercise your California privacy rights, contact us at support@holingo.org with the subject "California Privacy Rights Request." We will verify your identity before processing your request.

Holingo is not directed at children under 13 years of age. We do not knowingly collect, use, or disclose personal information from children under 13. If you believe that we may have inadvertently collected personal information from a child under 13, please contact us immediately at support@holingo.org with the subject "COPPA Concern." We will take prompt steps to investigate and delete any such information. For users between 13 and 18 years of age, we encourage parents or guardians to review this Privacy Policy and to monitor their child's use of the Service. By registering an account, a user between 13 and 18 represents that their parent or legal guardian has reviewed and consented to these terms. We do not knowingly use targeted advertising or third-party tracking on accounts of users under 18.

Holingo operates primarily from servers located in the United States (or the jurisdiction where our hosting provider's infrastructure is based). If you are accessing the Service from outside the United States — including from the European Economic Area, the United Kingdom, Canada, Australia, or any other jurisdiction — your personal data may be transferred to and processed in the United States or other countries whose data protection laws may differ from those in your country. By using the Service, you acknowledge and agree to this transfer of your personal data to countries that may have different (including potentially less stringent) data protection rules than your own country. We take steps to ensure that any such transfers comply with applicable data protection law and that your data remains protected to the standard described in this Policy, including through appropriate contractual safeguards with our service providers. If you are located in the EEA or UK and have concerns about international data transfers, please contact us at support@holingo.org.

We implement a variety of technical and organizational measures designed to protect your personal information from unauthorized access, loss, destruction, alteration, or misuse: Technical Measures: Session cookies are signed and encrypted with a server-side secret key. OTP codes are single-use and short-lived (10 minutes). Passwords are never stored — we use passwordless authentication. Database connections use encrypted protocols. API keys and credentials are stored as environment secrets and never exposed in client-side code. All data is transmitted over HTTPS/TLS. Organizational Measures: Access to production data is restricted to authorized personnel only. We review our security practices periodically and update them as needed. Limitations: Despite these measures, no security system is impenetrable. We cannot guarantee the absolute security of your data during transmission or storage. In the event of a data breach that poses a significant risk to your rights and freedoms, we will notify affected users and, where required by law, relevant supervisory authorities, within the timeframes required by applicable law. If you discover or suspect a security vulnerability in our Service, please report it responsibly to support@holingo.org with the subject "Security Disclosure." We appreciate responsible disclosure and will not pursue legal action against good-faith security researchers.

Our Service integrates with the following third-party services: DeepSeek AI (deepseek.com): Processes Bible chapter text (not personal data) to generate quiz questions. Subject to DeepSeek's own privacy policy. GitHub CDN (raw.githubusercontent.com): Delivers KJV Bible text. Subject to GitHub's privacy policy. ip-api.com: Used once at account registration to determine your approximate country from your IP address. Subject to ip-api.com's privacy policy. Email Delivery (SMTP via Namecheap hosting mail): Used to send authentication OTPs and notification emails to your registered email address. Subject to Namecheap's privacy policy. PayPal (paypal.com): Processes donations made through the Support page. Holingo does not store your payment card details. Subject to PayPal's privacy policy. The Service may contain links to third-party websites. These links are provided for your convenience only. We have no control over the content or privacy practices of those websites and encourage you to review their privacy policies before providing any personal information.

We may update this Privacy Policy from time to time to reflect changes in our practices, the Service, applicable law, or for other operational or legal reasons. When we make material changes, we will: (a) Update the "Last updated" date at the top of this Policy; (b) Notify you via email to your registered address; and/or (c) Display a prominent notice within the Service. Material changes include significant new uses of your personal data, new categories of data collected, new third-party sharing arrangements, or changes to your rights. Your continued use of the Service after the effective date of any changes constitutes your acceptance of the updated Policy. If you do not agree to the updated Policy, you must stop using the Service and may delete your account. We encourage you to review this Policy periodically.

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us: Email: support@holingo.org Please include a clear subject line indicating the nature of your request, such as: - "Privacy Policy Question" - "Data Access Request" - "Account Deletion Request" - "Data Portability Request" - "COPPA Concern" - "California Privacy Rights Request" - "Security Disclosure" We will acknowledge your inquiry promptly and respond in full within 30 days. For complex requests, we may need additional time and will notify you accordingly.