Data processing agreement (DPA)

Updated: September 12, 2026

This document describes how we process personal data as a controller, in relation to our subprocessors.

1. Roles of the parties

Recapio is the data controller for the email address and usage statistics of its users. Paddle.com is an independent controller for billing and payment data, as merchant of record.

2. Categories of data processed

Email address, language preference, notification consent, usage statistics (learning progress, correctness rate, own notes and flags). We do not process names, dates of birth, postal addresses, or card data.

3. Subprocessors

Cloudflare (Workers, D1, R2, cookie-less Web Analytics) for hosting and infrastructure; Paddle.com for payments, as merchant of record; an email provider for login codes and transactional notifications. Each subprocessor is engaged for purposes limited to the service it provides.

4. Duration and deletion

Personal data is retained for as long as the account is active. On account deletion, content and statistics are permanently removed; rows in the credit ledger are kept with an anonymized identifier, solely for accounting integrity.

5. Security measures

Passwordless authentication via a temporary code sent by email; request rate limiting; simultaneous-session detection; audit trail of administrative actions.

6. International transfers

Our subprocessors operate internationally distributed infrastructure; transfers rely on the standard contractual mechanisms offered by each provider.

7. Contact

For questions about data processing, you can contact us at the contact address published on the site.