Privacy policy

1. Who we are

Loquio is made by IOCODO LLC, a limited liability company registered in Wyoming, United States. We decide why and how the data described on this page is used, so under European data protection law we are its controller.

Postal address: 30 N Gould St Ste N, Sheridan, WY 82801-6317, United States
Email: support@iocodo.com

Use this email for anything about your data, including the requests described in Your rights.

2. What this policy covers

This policy covers the Loquio app on iOS and Android, and this page. Loquio is an app for learning American Sign Language (ASL), with lessons, spaced review and a camera check of your signing that runs on your device.

Here, "personal data" means any information about you as a person who can be identified, directly or indirectly. That includes identifiers such as a user ID, an installation ID or an App Check token, even when they do not contain your name.

3. Data kept on your device

Loquio keeps the following on your device, in the app's own storage:

• your learning progress, camera check results and review schedule
• when you first opened the app, and the time from then until the camera check first accepted or rejected your sign
• your preferences: appearance, language, whether reminders are on, privacy choices and your reason for learning
• whether you are 14, 16 or 18 or over, worked out, only when the app needs your age, from the year of birth you enter or from the age range your app store shares (neither the year nor the range is kept)
• sign reports waiting to be sent
• deletions that could not reach our servers or Firebase yet, which the app tries again the next time you open it
• the next reminder, which your device's operating system holds
• which version of our terms of use you accepted, and when

We do not receive any of this, unless another section of this policy says otherwise. If you back up your device with iCloud or Google, the backup can include a copy of this data, under Apple's or Google's terms. Uninstalling the app deletes this data from your device.

The app processes camera images on your device to detect the position of your hands, and never stores or sends them.

4. Accounts and sign-in

Loquio has no user accounts: you do not register or sign in. If you send a sign report, the app creates a random identifier, without your name or email address, so that you can delete your reports later.

5. What we use data for, and on what legal basis

European data protection law (the GDPR and the UK GDPR) requires a legal basis for each use of personal data. For each use, here is the data involved and the basis we rely on.

• Running the app: keeping it configured and confirming that requests come from the genuine app

  Data: installation identifiers, App Check tokens and an attestation from Apple's DeviceCheck or Google Play Integrity.

  Legal basis: Performance of our contract with you, that is, providing the app you asked for (GDPR art. 6(1)(b)).

• Handling the sign reports you choose to send

  Data: the sign identifier, your note, the sign language of the course (ASL), the date and a random identifier created for your reports.

  Legal basis: Performance of our contract with you, that is, providing the app you asked for (GDPR art. 6(1)(b)).

• Counting how the app is used

  Data: usage events, device model, operating system version, a coarse region that Google derives from your connection, the app-instance identifier and installation identifiers.

  Legal basis: Your consent, which the app asks for before this starts in the European Economic Area, the United Kingdom, Canada, Türkiye, Vietnam and Brazil (in the European Union and the European Economic Area, GDPR art. 6(1)(a); in the United Kingdom, the same article of the UK GDPR). In other countries it is on unless you turn it off. Everywhere, you can turn it off at any time in the app (Settings, then Privacy choices).

• Fixing crashes

  Data: crash reports with their diagnostics (memory and disk state), device model, operating system version and installation identifiers.

  Legal basis: Your consent, which the app asks for before this starts in the European Economic Area, Canada, Türkiye, Vietnam and Brazil (in the European Union and the European Economic Area, GDPR art. 6(1)(a)). In other countries it is on unless you turn it off. Everywhere, you can turn it off at any time in the app (Settings, then Privacy choices).

• Fixing crashes in the United Kingdom

  Data: crash reports with their diagnostics (memory and disk state), device model, operating system version and installation identifiers.

  Legal basis: Our legitimate interests (GDPR art. 6(1)(f)): finding and fixing the crashes you hit, which in the United Kingdom rests on article 6(1)(f) of the UK GDPR. The app does not ask first there, because the Privacy and Electronic Communications Regulations (PECR) allow storing and reading this data on your device without consent when it is needed only to find and fix technical faults. Crash reports are on unless you turn them off in the app (Settings, then Privacy choices). You can object at any time by writing to us.

• Answering you when you write to us

  Data: your email address, your message, anything you attach and, when you write from the app, the app version, the operating system and its version, and the app's language.

  Legal basis: Our legitimate interests (GDPR art. 6(1)(f)): answering your request, and keeping a record of how we handled it. You can object at any time by writing to us.

6. Who receives data

We use these service providers to run Loquio. Each one receives only the data listed, for the purpose listed:

• Google Analytics for Firebase (Google LLC)

  What for: counts how the app is used.

  Data: the events Firebase records by itself (app opens, sessions and the screens you view), an app-instance identifier, device model, operating system version and a coarse region that Google derives from your connection. The app also sends one event of its own, the first time the camera check accepts or rejects your sign: the time since you first opened the app, whether the sign was accepted or rejected, and which attempt that was. We use it to measure how long a new learner takes to get a first result from the camera check. Like the other events, it is sent only while usage statistics are on.

  Google LLC processes this data on our behalf, under its data processing terms. Google Analytics for Firebase privacy information

• Firebase Crashlytics (Google LLC)

  What for: reports crashes so we can fix them.

  Data: crash reports and diagnostics (device model, operating system, memory and disk state) with installation identifiers.

  Google LLC processes this data on our behalf, under its data processing terms. Firebase Crashlytics privacy information

• Firebase Remote Config and Firebase Installations (Google LLC)

  What for: keep the app configured, for example switching a feature off remotely.

  Data: an installation identifier.

  Google LLC processes this data on our behalf, under its data processing terms. Firebase Remote Config and Firebase Installations privacy information

• Firebase App Check (Google LLC)

  What for: confirms that requests come from the genuine app.

  Data: an attestation from Apple's DeviceCheck or Google Play Integrity and a short-lived App Check token.

  Google LLC processes this data on our behalf, under its data processing terms. Firebase App Check privacy information

• Firebase Authentication (Google LLC)

  What for: creates a random identifier, only when you send your first sign report, so your reports can be deleted later.

  Data: a random user identifier.

  Google LLC processes this data on our behalf, under its data processing terms. Firebase Authentication privacy information

• Cloud Firestore (Google LLC)

  What for: stores the sign reports you send.

  Data: the sign identifier, your note, the sign language of the course (ASL), the date and the random identifier.

  Google LLC processes this data on our behalf, under its data processing terms. Cloud Firestore privacy information

• GoDaddy Professional Email (GoDaddy Operating Company, LLC)

  What for: receives and keeps the emails you send to support@iocodo.com.

  Data: your email address, your message and anything you attach.

  GoDaddy Operating Company, LLC processes this data on our behalf, under its data processing terms. GoDaddy Professional Email privacy information

Apple (App Store) and Google (Google Play) also handle your download and any purchase, under their own privacy policies.

We do not sell your personal data.

7. Where data is processed

IOCODO LLC is registered in the United States. Our service providers may process your personal data in the United States and other countries where Google, GoDaddy or their subcontractors have facilities.

Where European, UK or Swiss data protection law requires a safeguard for this, we rely on:

• the EU-U.S. Data Privacy Framework, its UK Extension and the Swiss-U.S. Data Privacy Framework, for providers certified under them (you can check a provider on dataprivacyframework.gov)
• the Standard Contractual Clauses approved by the European Commission, with the UK Addendum and the Swiss adjustments, which are part of our providers' data processing terms

You can ask us for a copy of these safeguards at support@iocodo.com.

8. How long we keep data

Here is how long we keep each kind of personal data. Items marked automatic are deleted on a fixed schedule, without anyone having to ask.

• Usage events in Google Analytics

  2 months. automatic

• Crash reports

  90 days. automatic

• Sign reports

  Until we have handled them, or until you delete them in the app, whichever comes first.

• The random identifier for your sign reports

  Until you delete your data in the app.

• Installation identifiers

  Until you delete your data in the app, which asks Firebase to delete them (without a connection, the app asks again the next time you open it); Firebase then removes them within 180 days. If you uninstall the app without doing so, Firebase deletes them on its own once they have gone 270 days without use (its current rule).

• Emails you send us

  Until you ask us to delete them. We set no fixed end date: we keep them as the record of our support, to answer you if you write again and to show how we handled your request. If a law or a legal claim requires us to keep an email, we keep it until that ends.

• What the app keeps on your device

  Until you delete your data in the app, or until you uninstall the app. Deleting your data keeps three things: what you turned off in Privacy choices, which stays off; what your age answer turned off; and the deletions that could not reach our servers or Firebase yet, until they do.

When you delete your data in the app or ask us to delete it, we delete it as described here, unless the law requires us to keep part of it.

9. How we protect data

Data travels between the app and our service providers over encrypted connections (HTTPS).

Our providers encrypt the data they store for us, and the access rules of our database limit what each user can read and change. Access to our systems is limited to the people who run Loquio, and only to run and support it.

If a security incident puts your personal data at risk, we tell you and the competent authorities when the law requires it.

10. Your rights

Wherever you live, you can ask us to:

• tell you what personal data we have about you, and give you a copy
• send that copy to you, or to another company, in a machine-readable format
• correct data that is wrong or incomplete
• delete your data
• stop or limit a use of your data, including any use based on our legitimate interests

To ask, write to support@iocodo.com. It is free. We reply within one month, and we may ask you to confirm that the data is yours before we act.

You can also withdraw any consent you gave, at any time, in the app (Settings, then Privacy choices). This does not affect what we did with your data before you withdrew it.

Deleting your data

You can delete your data:

• in the app, for your progress, your preferences, your sign reports, the random identifier of your reports and the identifiers Firebase gave your installation: Settings, then Delete all my data
• on the web: iocodo.com/apps/loquio/delete-data
• by email: write to support@iocodo.com with the subject "Delete my data"

Usage statistics and crash reports that were already sent are deleted on their own, within the periods in How long we keep data.

What the app keeps on your device is deleted when you uninstall the app.

Complaints

You also have the right to complain to an authority:

• in the European Union and the European Economic Area, the data protection authority of the country where you live or work (list of authorities); in Italy, the Garante per la protezione dei dati personali
• in the United Kingdom, the Information Commissioner's Office
• in Switzerland, the Federal Data Protection and Information Commissioner
• in Brazil, the Agência Nacional de Proteção de Dados
• in the United States, the attorney general of your state

If you are in Brazil, you have the rights listed in article 18 of the LGPD (Lei 13.709/2018), and you can use them as described above.

11. Privacy rights in US states

Several US states, including California, Colorado, Connecticut, Oregon, Texas and Virginia, give their residents privacy rights. We give the same rights to everyone in the United States:

• to know what personal information we collect, use and disclose, and to get a copy of it
• to correct it
• to delete it
• to opt out of the sale of your personal information, of its use for targeted advertising and of profiling that has legal or similarly significant effects
• to appeal if we turn down your request
• not to be treated differently for using any of these rights

The personal information we collect comes from you and from the app on your device. Why we use it and who receives it are described in What we use data for and Who receives data. We do not sell your personal information. In the current version of Loquio, we do not use or share it for targeted advertising.

To use these rights, write to support@iocodo.com, or have someone you authorise write for you. We reply within one month (these state laws allow up to 45 days). If we turn your request down, you can appeal by replying with the word "Appeal" in the subject. We answer an appeal within 45 days, and if you still disagree you can contact the attorney general of your state.

12. Children

Loquio is not meant for children under 13.

The app does not ask your age when you first open it. Where it asks for your consent to usage statistics and crash reports, it asks for your year of birth only if you allow one of them, right after you do; in Italy, or when the app cannot tell where the phone is, it also asks before the first camera check. On phones where the app store shares an age range with the app (Apple's Declared Age Range, Google Play Age Signals), the app uses that range instead and asks only if the range is not enough; the range is used for this alone, and it is neither kept nor sent. The app keeps only whether you are 14, 16 or 18 or over, never the year. Your consent counts only if you are 14 or over in the United Kingdom and Canada, 16 or over in the European Economic Area and Vietnam, and 18 or over in Türkiye and Brazil: if you may be younger, what the app asks your consent for stays off there and cannot be turned on in the app. In the United Kingdom, crash reports follow their own rule whatever your age: they are on, and you can turn them off in Settings, then Privacy choices. In Italy, or when the app cannot tell where the phone is, if you may be under 14, the camera check stays off. An answer that keeps something off counts for a year; after that, the app asks again, only where it needs to. Deleting your data in the app keeps these answers.

If you think a child has given us personal data, write to support@iocodo.com and we will delete it.

13. "Do Not Track" and other companies

Some browsers and devices can send a "Do Not Track" signal. There is no common standard for responding to it, so neither Loquio nor this page changes what it does when it receives one. The choices described in this policy are how you control your data.

In the current version of Loquio, only the service providers listed in Who receives data receive data from the app, for the purposes listed there. We do not let other companies use Loquio to collect personal data about your activity over time and across other apps and websites.

14. Changes to this policy

We update this policy when Loquio or the law changes, and the date at the top shows when the current version took effect. If a change affects how we use data we already have about you, we tell you in the app before it applies, and we ask for your consent again where the law requires it.

This version was last updated on October 12, 2026.

Earlier versions: 2026-09-29, 2026-09-30, 2026-09-08

15. Contact

IOCODO LLC
Postal address: 30 N Gould St Ste N, Sheridan, WY 82801-6317, United States
Email: support@iocodo.com