Privacy Policy

Effective date: 1 January 2026

Last updated: 1 January 2026

This Privacy Policy explains how Almanac by Openmind (“Almanac,” “we,” “us”) collects, uses, and shares information when you use our website almanac.academy (the “Website”) and our Android and web applications (the “App”). Users in the EEA/UK/CH can choose between personalized ads, non-personalized ads, or rejecting advertising cookies. You can delete your account at any time.

Controller & Contact

Controller: Autónomo NIF 60809113B (trading as “Almanac by Openmind”)

Address: Carrer de Sa Romaguera 16, 07100 Sóller, Illes Balears, Spain

Email: hello@openmind.cx

Website: https://almanac.academy

Information We Collect

You provide

• Account data: name, last name, email, country; password (hashed).
• Support & communications: contents of emails sent to hello@openmind.cx.

Collected automatically

• Device/app data: device model, OS, app version, language, time zone.
• Identifiers: advertising ID (Android), device/install IDs, IP address (approx. location), RevenueCat app user ID.
• Usage & telemetry: events, session data, performance metrics.
• Crash/diagnostics: crash logs and error reports.
• Ads events: ad impressions, reward completions (incl. AdMob SSV payloads).
• Payments/entitlements: purchase tokens/receipts, Stripe customer ID, product IDs, subscription status via RevenueCat.
• Consent records: CMP/UMP consent string, timestamp, region, policy/version.

We do not intentionally collect special category data (e.g., health, religion).

Purposes & Legal Bases (EEA/UK)

• Provide the Service: accounts, sync, purchases, entitlements.
  Basis: Performance of a contract.
• Payments & subscriptions: Google Play, Stripe, RevenueCat.
  Basis: Contract; legal obligations.
• Advertising & monetization: Personalized ads only with consent; otherwise non-personalized.
  Basis: Consent / Legitimate interests.
• Analytics, improvement, security & fraud prevention.
  Basis: Legitimate interests.
• Communications: service emails, billing; marketing only with opt-in.
  Basis: Contract; consent for marketing.

You can withdraw consent anytime in the CMP/UMP panel; past processing remains lawful.

Cookies, SDKs & Consent

Cookies & Local Storage (Website)

The Website uses cookies, localStorage, and similar technologies for essential functionality, analytics, and advertising. Cookies may be set by us or by trusted partners such as Google Ad Manager, AdSense, and Google Analytics.

• Essential cookies: login, security, language, preferences.
• Analytics cookies: Google Analytics 4 for aggregated usage measurement.
• Advertising cookies: Google Ad Manager / AdSense to deliver personalized or non-personalized ads depending on your consent.
• LocalStorage: app settings, last session state, and interface preferences.

Data collected via advertising cookies may include IP address, device identifiers, coarse location, ad interactions, and browsing behavior within our Website.

Web (almanac.academy)

We use Google's certified Consent Management Platform (CMP) under the IAB TCF v2.2 framework. Users in the EEA/UK/CH can choose:

• Personalized ads
• Non-personalized ads
• Reject all advertising cookies

When consent is denied, we serve non-personalized ads and apply Google Consent Mode v2 to adjust analytics and advertising behavior.

CMP provider: Google CMP (Ad Manager “Privacy & Messaging”)

You can revisit or change your choices at any time from the “Privacy / Cookies” link in the footer.

Android

We use Google UMP to show the EEA/UK/CH consent flow. AdMob requests non-personalized ads if consent is denied.

Cookie collection and advertising on the Website comply with the EU ePrivacy Directive and GDPR. Non-essential cookies are used only after consent is given through our CMP.

Advertising & Rewarded Tokens

Android: AdMob Rewarded; tokens confirmed via SSV.

Web: Google Ad Manager Rewarded.

Default: +15 tokens, up to 3 rewards/hour.

Payments & Subscriptions

Android: Google Play Billing; entitlements via RevenueCat.

Web: Stripe Checkout; entitlements via RevenueCat.

Products: premium_monthly, premium_yearly, token packs. Digital access may affect withdrawal rights under local law. We don’t store full payment card data.

Service Providers & Partners

• Ads: Google AdMob, Google Ad Manager, Google AdSense.
• Purchases: Google Play, Stripe, RevenueCat.
• AI Tutor: Google Gemini API — processes chat messages submitted in the demo tutor on the home page. Messages are ephemeral and not stored in our database. No personal data should be submitted via this chat.
• Analytics/Diagnostics: Firebase, Google Analytics 4 (GA4), Crashlytics, Sentry.
• Hosting: DigitalOcean.
• Email: Direct SMTP.
• Auth: Own backend + Google Sign-In.
• Parental consent: Kids Web Services (KWS) — used to obtain and record verifiable parental consent for users under 13. KWS processes the parent's email address solely for this purpose. KWS Privacy Policy: kidswebservices.com/privacy-policy.

International Transfers

We are based in Spain (EU). Transfers outside the EEA/UK use SCCs or equivalent safeguards from our vendors.

Retention

• Account data: until deletion or no longer needed.
• Ad/analytics data: ≤13 months.
• Crash logs: ≤90 days.
• Backups: ~30-day rolling.

Your Rights (EEA/UK/CH)

You may request access, correction, deletion, restriction, objection, portability, and withdraw consent. Email: hello@openmind.cx. You may complain to your local authority (e.g. AEPD Spain).

Children and Parental Consent (COPPA / GDPR-K)

We allow users under 13 (and under the applicable digital age of consent in their jurisdiction, e.g., 14 in Spain) to register only after a parent or guardian provides verifiable parental consent through our partner Kids Web Services (KWS). Access is restricted until consent is confirmed.

What we collect from children: name, email address, country, and usage data necessary to provide the Service (progress, session data, crash logs). We do not collect special category data from children.

How we use children’s data: solely to provide and improve the educational Service. We do not use children’s data for behavioral profiling, personalized advertising, or marketing. Ads shown to users under 13 are served in child-directed / non-personalized mode (COPPA-compliant, TFUA flag enabled on ad requests).

Parental rights: Parents or guardians may at any time:

• Review the personal data collected from their child.
• Request correction or deletion of their child’s data.
• Revoke consent and request account closure.
• Refuse further collection or use of their child’s data without affecting their child’s right to use the Service where possible.

To exercise these rights, email us at hello@openmind.cx with the subject "Parental Request." We will respond within 30 days.

If you believe a child’s data has been collected without proper consent, contact us immediately at hello@openmind.cx and we will delete it promptly.

Security

We use encryption in transit, access controls, and least-privilege principles. No system is perfectly secure, but we continuously improve protections.

Changes

We may update this policy; changes will be posted with a new “Last updated” date and, when required, users will be notified.

Contact

Almanac by Openmind
Carrer de Sa Romaguera 16, 07100 Sóller, Illes Balears, Spain
hello@openmind.cx