Privacy Policy
This policy explains what data we collect, how we use it, who we share it with, and what rights you have. Applicable to users who have reached the digital consent threshold in their country.
This policy applies to users who have reached the digital consent threshold in their country. If you are a minor, see our Privacy Policy for Minors.
1. Data controller
Mitosk is the controller of your personal data. For any privacy-related questions, contact us at [email protected].
2. What data do we collect?
2.1. Data you provide directly
- Registration: email address, alias (username), date of birth and password (stored as a one-way hash). If you register with Google or Apple, we receive your unique identifier, email address and associated name; never your password.
- Preferences: selected language and chosen personality for the character Ratatosk.
- User Content: free text, PDFs and images you supply to create Worlds. It is processed to generate the World and may form part of private inputs or artefacts needed to resume or review the process. Immediate deletion on completion is not guaranteed; the actual retention period must be settled before public launch.
- Tutor interactions: conversations with Ratatosk are stored while your account is active to maintain your history and improve your experience.
- Moderation data: if you report a World or receive a warning, identifiers, metadata and, where necessary to handle the incident, evidence subject to restricted access are recorded.
2.2. Data generated by your use of the Service
- Progression and metrics: correct answers, mistakes, response times, completed levels, streaks, league positions and game statistics.
- In-game economy: virtual currency balance, item inventory, transaction history and Premium Plan purchases.
- Social data: friends list, invitations, and participation in leagues and multiplayer. Other users see only your alias, avatar and basic statistics; never your email address or date of birth.
2.3. Technical data collected automatically
- Device: platform (iOS/Android/Web), device language and push notification tokens (Firebase Cloud Messaging).
- Session: date and time of last access, date of last energy regeneration.
- Payment: if you purchase the Premium Plan via the web, Stripe processes the payment; Mitosk stores only Stripe's customer and subscription identifiers, never your card details. Purchases in stores (App Store / Google Play) are managed directly by those stores.
- Daily activity: one record for each day you use Mitosk, showing which time slots (in UTC) you were active in. This is a daily summary, not a history: we do not store a timestamp for every screen you open or what you did in each slot. It tells us how many people use the Service and when, without tracking your activity step by step.
- Session duration: the time the app remains open in the foreground, measured on your device, together with the platform (iOS/Android) and app version. Time spent in the background is not counted.
2.4. Data we do NOT collect
Mitosk does not collect your real name (unless you choose it as your alias), postal address, telephone number, biometric data, precise geolocation or photographs of you. Images used to create Worlds pass through filters that automatically reject faces and identifiable images. We store the time zone reported by the app to determine the day of play and streak. Administrative statistics are aggregated in UTC. None of this technical data records which content you view.
3. What do we use your data for, and on what legal basis?
| Purpose | Data used | Legal basis |
|---|---|---|
| Creating your account, authenticating you and managing your profile | Email, alias, date of birth, password/OAuth, preferences | Performance of a contract (Art. 6.1.b GDPR) |
| Generating Worlds with AI | User Content (material and generation artefacts), Tutor queries | Performance of a contract (Art. 6.1.b) |
| Maintaining conversational Tutor history | Conversations with Ratatosk | Performance of a contract (Art. 6.1.b) |
| Managing progression, leagues, multiplayer and the economy | Metrics, statistics, economic data, social data | Performance of a contract (Art. 6.1.b) |
| Processing Premium Plan and Virtual Currency payments | Stripe identifiers, subscription data | Performance of a contract (Art. 6.1.b) |
| Sending push notifications | FCM tokens, platform | Performance of a contract (Art. 6.1.b) |
| Operational email communications (verification, moderation) | Performance of a contract (Art. 6.1.b) | |
| Moderating content and ensuring security | Incident identifiers, hashes | Legitimate interest (Art. 6.1.f): platform security |
| Non-personalised contextual advertising (free plan) | Screen context (no profile) | Legitimate interest (Art. 6.1.f) |
| Personalised advertising (adults only, with consent) | Usage data managed by AdMob | Consent (Art. 6.1.a), managed by CMP/UMP |
| Technical evaluation and Service improvement | Results, metrics and generation records depending on the plan and configuration; these may contain personal data | Legal basis, exclusions and conditions to be settled before activating this processing in production; anonymisation is not presumed |
| Responding to professional enquiries and preparing a proposal | Name, email, organisation, plan of interest, approximate size, message and follow-up/email statuses | Requested pre-contractual measures (Art. 6.1.b), where applicable; for professional contacts at an entity, a legitimate interest in handling the enquiry (Art. 6.1.f) |
| Complying with legal obligations | Transaction data, moderation records | Legal obligation (Art. 6.1.c) |
4. Transformative processing: what we do with your material
Mitosk radically transforms the material you supply into educational content of a completely different nature: exercises, study cards, mini-games, podcasts and summaries. Processing may create working copies, inputs and private artefacts to resume or review generation. Results and references are also retained to display the World and ground the Tutor's responses. Transforming text does not demonstrate anonymisation or rule out the presence of personal data.
To perform this transformation, your material is transmitted to AI Providers during generation. Before public launch, the terms of each activated provider, training options, regions and, where applicable, data processing agreements and transfer safeguards must be substantiated. This draft does not establish that those contracts have been signed.
5. Who do we share your data with?
| Recipient | Data | Purpose | Safeguards |
|---|---|---|---|
| Google (Gemini / Vertex AI) | User Content (material and generation artefacts), Tutor queries | World generation and Tutor responses | Verify the activated service, region, role and processing terms before production. |
| Mistral | User Content (material and generation artefacts), queries | Content generation and processing | Verify the activated service, region, role and processing terms before production. |
| Groq | User Content (material and generation artefacts), queries | Generation and processing | Verify the activated service, region, role and processing terms before production. |
| Fireworks | User Content (material and generation artefacts), queries | Generation and processing | Verify the activated service, region, role and processing terms before production. |
| Tavily | AI-generated search queries | “Expand content” feature | Verify the activated service, region, role and processing terms before production. |
| Google AdMob | Device advertising identifiers (adults with consent; contextual for minors) | Advertising in the free plan | Google Ads policies. Consent managed by UMP. |
| Firebase (Google) | FCM tokens, platform | Push notifications | Google infrastructure. No content data. |
| Stripe | Payment data (processed by Stripe; Mitosk stores only identifiers) | Web payments for the Premium Plan and Virtual Currency | PCI DSS certified. Mitosk never sees or stores card data. |
| Apple App Store / Google Play | In-app payment data (managed entirely by the Stores) | In-app purchases | Each Store's policies. |
| Cloudflare | Web traffic, security checks, subscriptions and hosted files/artefacts depending on the service (Pages, Turnstile, D1 and R2) | Hosting, storage and protection of the Service | Verify the activated service, region, role and processing terms before production. |
| Google Cloud Platform | All Service data | Backend hosting | Verify the activated service, region, role and processing terms before production. |
| Google Analytics | Browsing data and identifiers depending on configuration and consent | Website measurement when enabled and with the appropriate consent | Verify the activated service, region, role and processing terms before production. |
Mitosk does not sell personal data to third parties or share it for advertising beyond the Ad Network (and only with your consent for personalised advertising, if you are an adult).
Professional enquiry emails: Resend receives the data needed to send the confirmation and internal notification, including the enquiry text in the latter. Receipt of the enquiry is retained in the backend even if email fails. The provider's terms, subprocessors, region and retention must be verified before production emails are enabled.
6. International data transfers
The Service combines hosting, storage and email infrastructure with AI providers. There is no guarantee that all processing takes place in a single region. Before public launch, actual destinations, subprocessors and the mechanism applicable to each transfer outside the EEA must be documented; the location of a provider's headquarters does not in itself establish where it processes data.
7. How long do we retain your data?
| Category | Retention period |
|---|---|
| Account data (email, alias, preferences) | While the account is active. Deleted when it is closed. |
| Source material and private generation artefacts | Retention needed to process, resume and review generation. The maximum period and automatic deletion must be settled and verified before public launch. |
| Generated Content and the World's dense summary | For as long as the World exists. Deleting the World deletes its content and embeddings. |
| Conversational Tutor history | While the account is active. You may request deletion at any time. |
| Learning metrics and progression | While the account is active. |
| Economic data (transactions, subscriptions) | While the account is active and for the legally required period for tax obligations after closure. |
| Moderation records | Identifiers, metadata and necessary evidence, with restricted access, to handle and review incidents. Worlds under review are purged after 90 days if unresolved. |
| FCM tokens | While active; revoked on sign-out or account closure. |
| Inactive accounts | Mitosk may delete accounts with no access for 24 consecutive months, after prior notification by email. |
| Evaluation captures and generation metrics | They may contain personal data. They require verifiable retention periods and erasure; they will not be kept indefinitely on an assumption of anonymity. Processing in production remains to be validated. |
| Professional enquiries, CRM and pending emails | While handling the enquiry and, where applicable, the pre-contractual or contractual relationship and its applicable obligations. Closure criteria and the purge period must be settled before production intake is enabled; retrying an email does not remove the enquiry from the CRM. |
| Daily activity and session duration | Daily activity: 400 days. Session duration: 90 days. They are deleted automatically after those periods. |
When you close your account, deletion of associated data is processed, subject to applicable retention exceptions and obligations. Removing author identifiers does not in itself demonstrate that a Public World is anonymised. Professional enquiries and financial records may have purposes and retention periods distinct from those of the game account. The actual procedures and their limits must be verified before public launch.
8. Your rights
Under the GDPR, you have the right to:
- Access: obtain a copy of the personal data we process about you.
- Rectification: correct inaccurate or incomplete data.
- Erasure: request deletion of your data. You may close your account at any time from the app, triggering actual deletion of your data.
- Restriction: ask us to restrict the use of your data in certain circumstances.
- Portability: receive your data in a structured, commonly used format.
- Objection: object to processing based on legitimate interest.
- Withdrawal of consent: where processing is based on consent (e.g. personalised advertising), you may withdraw it at any time without affecting the lawfulness of prior processing.
To exercise these rights, contact [email protected]. We will respond within one month, extendable to two months in complex cases.
If you believe the processing of your data is not compliant, you may lodge a complaint with the Spanish Data Protection Authority (AEPD) or the supervisory authority in your country of residence.
9. Advertising and cookies
The free tier is funded by advertising served by the Ad Network (Google AdMob). For adult users in the European Union, consent is requested before personalised advertising is served through the Consent Management Platform (CMP/UMP) integrated into the app. You can change your preferences at any time in settings.
Cookies and equivalent technologies essential to the web Service (authentication, session) do not require consent. Non-essential ones are activated only with your prior consent. See our Cookie Policy for more information.
On the website, Mitosk uses Google Analytics 4 with Consent Mode v2. A banner on your first visit lets you accept or reject analysis of your browsing. If you reject it, no analytics cookies are installed and no personal data is transmitted to Google. You can change your preference at any time by clearing your browser cookies.
10. Security
Mitosk applies technical and organisational measures to protect your data: password encryption (bcrypt), storage on Google Cloud infrastructure with security certifications, encrypted communications (HTTPS/TLS), authentication using expiring tokens, role-based access control and automated content monitoring.
11. Evaluation records and plans
The code distinguishes plans for evaluation captures. Production configuration must respect the exclusions communicated at purchase; debugging modes must not bypass them. Processing needed to provide the Service, ensure security and meet legal obligations is distinct from model improvement or training.
12. Changes to this policy
Mitosk may update this Privacy Policy. Material changes will be communicated through the app's news system and, where appropriate, by email. The current version will always be available at mitosk.com/en/legal/privacidad/.