PRIVACY POLICY
Dona - Oral Language Practice Community
Effective Date: May 25, 2026
Contact: service@dona.ink
This Privacy Policy ("Policy") describes how Dona ("we," "our," or "us") collects, uses, stores, shares, and protects your personal information when you use the Dona mobile application and related services (collectively, the "Service"). By accessing or using Dona, you confirm that you have read, understood, and agreed to be bound by this Policy. If you do not agree with any part of this Policy, please discontinue use of the Service immediately.
1. Introduction and Scope
1.1 About This Policy. This Privacy Policy applies to all users of the Dona mobile application, available on iOS and Android platforms worldwide. It governs the collection, processing, and protection of personal data in connection with your use of Dona's features, including daily speaking check-ins, community audio sharing, AI coaching, and progress tracking.
1.2 Who We Are. Dona is an oral language practice community designed for adult learners aged 18 and above across the globe. We are committed to maintaining user trust through transparency about how we handle personal information and by implementing robust privacy protections aligned with applicable laws.
1.3 Applicability. This Policy applies to all registered users and visitors of the Dona application; users interacting with in-app features including audio recordings, community posts, AI coaching sessions, and token transactions; and users across all geographic regions including the EEA, UK, US, Asia-Pacific, Latin America, and Africa.
1.4 Relationship to Other Policies. This Privacy Policy should be read alongside our Terms of Service and Community Guidelines. Where specific features involve additional data practices, supplemental notices may be provided at the point of collection.
2. Information We Collect
2.1 Account and Registration Information. When you create a Dona account, we may collect: your username or display name; email address or phone number; encrypted password; profile photo or avatar; language learning preferences and native language; and age verification confirmation (18+).
2.2 User-Generated Content (UGC). Dona collects the following content you create: audio recordings submitted for daily check-ins; audio clips and posts shared to the community feed; text captions, tags, or descriptions accompanying your posts; comments, likes, and reactions on other users' content; and any written feedback or messages exchanged within the platform.
2.3 Device and Technical Information. We automatically collect: device identifiers (device ID, advertising ID, IDFA/GAID); operating system type and version; app version and build number; IP address and inferred approximate geographic location (country or region level); crash reports, performance logs, and diagnostic data; and time zone and system language settings.
2.4 Usage and Behavioral Data. We collect data about how you interact with Dona, including: features accessed and frequency of use; daily check-in history, completion dates, and streak records; audio content playback behavior; AI coaching session logs; token balance history and spending transactions; and search queries entered within the app.
2.5 Communications and Support. If you contact our support team, we retain records of: the content of your messages or support tickets; your contact details; and any files you voluntarily share with us for support purposes.
3. How We Use Your Information
3.1 Service Delivery and Core Functionality. We use your data to: create and maintain your user account; generate and deliver your personalized daily speaking scenario; store and display your audio recordings and community posts; process AI coaching requests; manage your token balance; and track your daily check-in history and overall progress.
3.2 Personalization and Recommendation. We use your learning preferences, usage history, and engagement behavior to: recommend relevant community posts and audio content; adjust scenario difficulty based on your proficiency signals; surface personalized AI coaching insights; and notify you of milestones, streaks, and community activity that may interest you.
3.3 Safety, Security, and Fraud Prevention. We process certain information to: detect, investigate, and prevent fraudulent activity, spam, or abuse; identify violations of our Terms of Service; verify user identity when required; and screen uploaded content for harmful or prohibited material using automated and human review systems.
3.4 Product Improvement and Research. We analyze aggregated and anonymized usage data to: understand feature interaction patterns; conduct internal research on language learning behaviors; test new features through A/B experiments; and generate insights that inform our product roadmap.
3.5 Legal Compliance and Enforcement. We may use your information as required or permitted by law: to comply with applicable legal obligations, court orders, or regulatory requirements; to respond to lawful requests from government authorities; and to enforce our Terms of Service and protect our rights.
3.6 Communications. With your consent where required, we use your contact information to: send service-related notifications; notify you of new features and app improvements; and deliver promotional communications (you may opt out at any time).
4. Legal Basis for Processing Personal Data
4.1 Applicability. This section is particularly relevant to users in the EEA, UK, and other jurisdictions requiring a lawful basis for processing personal data under applicable data protection law.
4.2 Contractual Necessity. Much of our data processing is necessary to perform our contract with you (the Terms of Service), including: providing account functionality and core app features; delivering AI coaching results; and storing and displaying your community posts and recordings.
4.3 Legitimate Interests. We process certain data based on our legitimate interests, including: improving the performance and security of our Service; preventing fraud and abuse; and conducting internal analytics to understand product usage trends.
4.4 Consent. Where we rely on consent (e.g., for marketing communications, optional personalization, or microphone access), you have the right to withdraw that consent at any time without affecting the lawfulness of prior processing. Withdrawal can be managed through in-app settings or by contacting service@dona.ink.
4.5 Legal Obligation. We may process your data where necessary to comply with a legal obligation, including applicable data protection legislation, financial regulations, and law enforcement obligations.
5. Information Sharing and Disclosure
5.1 No Sale of Personal Data. We do not sell your personal information to third parties for their own marketing or commercial purposes. Any sharing of data is conducted only as described in this Policy.
5.2 With Your Explicit Consent. We will share your personal information with third parties only when you have given us explicit, informed consent, such as when you choose to link a third-party account or authorize an integration.
5.3 Service Providers and Vendors. We engage trusted third-party companies to assist in operating the Service, including: cloud infrastructure and hosting providers; analytics platforms; push notification delivery services; payment processors; fraud detection services; content moderation services; and customer support tools. All providers are contractually restricted to use your data only for specified purposes and must implement adequate security safeguards.
5.4 Business Transfers. In the event of a merger, acquisition, reorganization, or sale of assets, your personal data may be transferred to the successor entity. We will provide prior notice via email and/or prominent in-app notice, and any successor will be required to honor this Policy.
5.5 Legal and Regulatory Disclosure. We may disclose your information to law enforcement or regulatory authorities when: legally required by court order or applicable law; reasonably necessary to prevent harm, fraud, or illegal activity; or needed to protect the rights, property, or safety of Dona, our users, or the public.
5.6 Aggregated and Anonymized Data. We may share aggregated, de-identified data with third parties including research partners and industry analysts for research and product development. This data does not identify any individual user.
5.7 Community Content. When you share audio recordings or posts to the Dona community feed, that content is visible to other registered users globally. Please exercise discretion and avoid disclosing sensitive personal information in public-facing content.
6. Third-Party Services and SDKs
6.1 Integrated Third-Party Tools. Dona integrates third-party SDKs and services to deliver certain features. These third parties may independently collect data through their tools. We encourage you to review their privacy policies, as they govern their own data practices.
6.2 Analytics Services. We use analytics SDKs to measure app performance and user engagement. These tools may collect device identifiers, session length, feature interaction events, and other non-personally identifying usage data.
6.3 Payment Processors. All in-app purchases and token transactions are processed through Apple's App Store or Google Play billing systems. Dona does not directly collect or store your payment card details. Financial information submitted is governed by Apple's or Google's respective privacy policies.
6.4 AI and Machine Learning Providers. Our AI coaching feature may be powered in part by third-party machine learning APIs. Audio data submitted for AI coaching may be transmitted to these providers in a secure, encrypted format. We contractually restrict providers from using your audio data for any purpose other than delivering coaching results.
6.5 Social Authentication. If you register or log in using a third-party service (e.g., Apple Sign-In, Google Sign-In), we may receive limited profile information from that provider in accordance with your permissions and their privacy policies.
6.6 Advertising. Dona does not currently serve third-party behavioral advertising to users. Should this change in the future, we will update this Privacy Policy and provide appropriate notice and opt-out mechanisms.
7. User-Generated Content (UGC) Policy
7.1 Nature of UGC on Dona. Dona is a community-centered oral language practice platform. User-generated content (UGC) is central to the experience and includes audio recordings, voice posts, text captions, comments, and profile materials submitted by users.
7.2 Collection and Storage of UGC. All UGC submitted through the app is collected and stored on our secure servers. Audio files uploaded for daily check-ins and community posts are retained in their original format and linked to your account.
7.3 How UGC Is Used. Your UGC may be used for: displaying your posts within the community feed for other users; processing your audio recordings through AI coaching tools; improving the accuracy of our AI coaching models using aggregated, de-identified audio data; providing you with a personal archive of your speaking progress; and content moderation and safety review.
7.4 Intellectual Property in UGC. You retain all intellectual property rights in the original content you create and upload to Dona. By submitting UGC, you grant Dona a non-exclusive, worldwide, royalty-free license to host, store, reproduce, display, and distribute your content solely for the purpose of operating and improving the Service. This license terminates when you delete your content or close your account, subject to any legal retention obligations.
7.5 Prohibited Content. Users are strictly prohibited from uploading UGC that: contains hate speech, harassment, threats, or discriminatory language; includes nudity, sexual content, or material that sexualizes minors; promotes violence, self-harm, terrorism, or illegal activities; infringes on third-party intellectual property rights; or is deceptive, misleading, or constitutes spam. Violations may result in content removal, account suspension, and reporting to relevant authorities.
7.6 Content Moderation. Dona employs a combination of automated content filters and human review to detect and remove content that violates our guidelines. We reserve the right to remove any UGC that violates our policies or applicable law.
7.7 User Reporting. Users may report UGC that violates our policies using the in-app report function available on each post. Reports are reviewed by our moderation team in a timely manner.
8. AI Coaching Features and Data Processing
8.1 How the AI Coaching Feature Works. Dona's AI coaching feature allows users to submit their recorded audio in exchange for personalized feedback on pronunciation, fluency, vocabulary use, and speaking rhythm. Access to AI coaching requires the expenditure of in-app tokens.
8.2 Data Transmitted for AI Processing. When you initiate an AI coaching session, the following data is transmitted: your audio recording for the submitted check-in or post; contextual metadata such as the target language, scenario type, and session timestamp; and optional text context such as the scenario prompt associated with the recording.
8.3 AI Feedback and Output. The AI coach generates textual feedback based on its analysis of your submitted audio. This feedback is returned to you within the app and stored in your coaching history for your future reference.
8.4 Data Use Limitations for AI Training. We may use aggregated and de-identified audio and feedback data to improve the quality of our AI coaching models over time. We will not use individually identifiable audio recordings for AI training purposes without first obtaining your explicit consent.
8.5 Third-Party AI Providers. Our AI features may rely on third-party machine learning infrastructure. All third-party AI providers are bound by data processing agreements that limit their use of your data to service delivery only, prohibit secondary use or re-sale, and require appropriate security measures.
8.6 Limitations and Disclaimer. AI-generated coaching feedback is intended for educational and informational purposes only. It does not constitute professional language instruction. Users are encouraged to supplement AI feedback with human instructors or other certified resources.
9. In-App Token System and Transaction Data
9.1 Overview of the Token System. Dona operates a virtual token economy that allows users to access premium features such as AI coaching sessions. Tokens may be earned through in-app activity (e.g., completing daily check-ins) or purchased through the App Store or Google Play.
9.2 Transaction Data We Collect. In connection with token-related activity, we collect and retain: records of token purchases including amount, timestamp, and platform identifier; token earning events linked to your account activity; token spending history; and order reference numbers provided by Apple or Google upon purchase completion.
9.3 Payment Processing. All purchases are processed exclusively through Apple In-App Purchase or Google Play Billing. Dona does not collect, process, or store your credit card, debit card, or banking information. For billing disputes or refunds, users must contact Apple or Google directly.
9.4 Token Validity and Expiration. Token balances and expiration conditions are governed by our Terms of Service. Tokens are non-transferable, have no cash value, and cannot be exchanged for real currency. Dona reserves the right to modify the token system with appropriate advance notice.
9.5 Fraud Detection. We monitor token transactions for signs of fraudulent activity, unauthorized manipulation, or abuse. Where fraudulent activity is detected, we reserve the right to suspend account access, forfeit token balances, and pursue appropriate legal remedies.
10. Data Retention and Deletion
10.1 Retention Principles. We retain your personal data only for as long as necessary to fulfill the purposes described in this Policy, or as required or permitted by applicable law. Retention periods vary depending on the type of data and context in which it was collected.
10.2 Active Account Data. While your account remains active, we retain: account and profile information for the duration of your account's existence; audio recordings and UGC linked to your account; usage and behavioral data for up to 24 months on a rolling basis; and AI coaching session logs for up to 12 months.
10.3 Deleted Content. When you delete a specific post or recording, we will remove it from public-facing surfaces within a reasonable timeframe. Copies may persist in backup systems for up to 90 days before being permanently purged.
10.4 Account Deletion. When you request account deletion, we will: remove your profile and account data from our active systems within 30 days; purge associated audio recordings, community posts, and personal data from our servers within 90 days; and retain certain data as required by applicable law (e.g., financial transaction records for up to 7 years, or data subject to active legal proceedings).
10.5 Anonymization. In some cases, rather than deleting data, we may anonymize it such that it can no longer be linked to you. Anonymized data may be retained indefinitely for analytics and product improvement purposes.
10.6 How to Request Deletion. You may request data deletion through the in-app account settings menu or by contacting us at service@dona.ink. We will acknowledge your request within 5 business days and complete the process within the timeframes described above.
11. Data Security
11.1 Our Commitment to Security. We take the security of your personal information seriously and implement technical, organizational, and administrative safeguards designed to protect your data against unauthorized access, disclosure, alteration, loss, or destruction.
11.2 Technical Safeguards. Our security measures include: encryption of data in transit using industry-standard Transport Layer Security (TLS) protocols; encryption of sensitive data at rest; access controls restricting data access to authorized personnel only; regular vulnerability assessments, penetration testing, and security audits; and secure server environments hosted with compliance-certified cloud infrastructure providers.
11.3 Organizational Safeguards. We implement internal policies including: role-based access to personal data on a need-to-know basis; employee training on data protection and privacy practices; confidentiality obligations for all staff and contractors; and incident response procedures for detecting, reporting, and addressing data breaches.
11.4 Data Breach Response. In the event of a data security breach posing a risk to your rights and freedoms, we will: investigate and contain the breach promptly; notify affected users and relevant regulatory authorities within legally required timeframes (e.g., 72 hours under GDPR); and provide clear guidance on steps you can take to protect yourself.
11.5 Your Role in Security. While we take all reasonable steps to protect your data, no system is entirely immune from risk. We encourage you to: use a strong, unique password; log out of your account when using shared devices; and notify us immediately at service@dona.ink if you suspect unauthorized access to your account.
12. Children's Privacy and Protection Against Child Sexual Abuse and Exploitation (CSAE)
12.1 Minimum Age Requirement. Dona is intended exclusively for users who are 18 years of age or older. We do not knowingly collect, use, or disclose personal information from individuals under the age of 18. By registering for and using Dona, you confirm that you are at least 18 years old.
12.2 No Knowing Collection from Minors. If we discover or have reason to believe that a user is under the age of 18, we will: immediately suspend access to that account; delete all personal data associated with that user from our systems; and take appropriate steps to prevent further access.
12.3 Age Verification. We implement reasonable age verification mechanisms at the point of registration, including age confirmation and, where required, additional verification steps. We may use third-party tools to assist in verifying user age in compliance with applicable regulations.
12.4 Parental and Guardian Reporting. If you are a parent or legal guardian and believe that your child under the age of 18 has created a Dona account without your consent, please contact us immediately at service@dona.ink. We will promptly investigate and take appropriate corrective action.
12.5 Child Sexual Abuse and Exploitation (CSAE) Policy. Dona maintains a zero-tolerance policy toward Child Sexual Abuse and Exploitation (CSAE) in any form. This commitment is reflected in our platform policies, technical safeguards, and legal obligations:
• Prohibition: The upload, sharing, distribution, promotion, or facilitation of any content that constitutes child sexual abuse material (CSAM), or that sexually exploits, solicits, grooms, or endangers minors, is strictly prohibited on Dona in any form, including audio, text, links, and metadata.
• Detection: We employ automated content scanning tools and human moderation to detect and remove any CSAE-related content. These tools are updated regularly to reflect evolving threat patterns.
• Immediate Removal: Any content identified as constituting or facilitating CSAE will be removed immediately upon detection, and the associated account will be permanently suspended.
• Reporting to Authorities: We are legally obligated to, and will, report any identified CSAM to the National Center for Missing and Exploited Children (NCMEC) and to relevant local law enforcement authorities in applicable jurisdictions. We fully cooperate with law enforcement investigations.
• No Safe Harbor: Dona will not provide any platform functionality, appeals process, or exception for content or behavior that constitutes CSAE. Such violations result in immediate and permanent account termination with no possibility of reinstatement.
12.6 Complying with COPPA and Similar Laws. To the extent applicable, we comply with the Children's Online Privacy Protection Act (COPPA) in the United States, the UK's Age Appropriate Design Code, and other applicable laws designed to protect the privacy and safety of minors.
13. User Rights and Choices
13.1 Overview of Your Rights. We respect your right to control your personal information. Depending on your jurisdiction, you may have certain rights with respect to the personal data we hold about you. These rights can be exercised by contacting us at service@dona.ink or through the in-app settings.
13.2 Right to Access. You have the right to request a copy of the personal data we hold about you, including: a description of the categories of personal data collected; the purposes for which we use your data; third parties with whom your data has been shared; and a portable copy in a commonly used format where technically feasible.
13.3 Right to Correction. You have the right to request that we correct any inaccurate or incomplete personal data. Many data fields (such as your profile name, email, and language preferences) can be updated directly through the in-app account settings.
13.4 Right to Deletion. You have the right to request deletion of your personal data, subject to certain legal exceptions (e.g., where retention is required by law or for the establishment of legal claims). To request deletion, use the in-app account deletion feature or email service@dona.ink.
13.5 Right to Withdraw Consent. Where we process your data based on consent, you may withdraw that consent at any time by: revoking microphone permissions through your device settings; opting out of marketing communications via the unsubscribe link or in-app notification settings; or contacting us at service@dona.ink.
13.6 Right to Object and Restrict Processing. In certain circumstances, you have the right to object to or request restriction of our processing of your personal data, particularly where processing is based on legitimate interests or where you contest the accuracy of the data.
13.7 Right to Data Portability. Where technically feasible, and where processing is based on consent or contract, you have the right to receive your personal data in a structured, commonly used, machine-readable format, and to transmit that data to another service provider.
13.8 Response Timeframes. We will acknowledge all rights requests within 5 business days and complete all verifiable requests within 30 days, or within the timeframe required by applicable law. We may request identity verification before processing a rights request to protect your account security.
14. California Residents - CCPA/CPRA Rights
14.1 Applicability. This section applies to users who are residents of the State of California and supplements the other information in this Privacy Policy. It is provided in accordance with the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA).
14.2 Categories of Personal Information Collected. In the preceding 12 months, we have collected the following categories of personal information: identifiers (name, email, device ID); audio and visual information (voice recordings, profile photos); commercial information (token purchase history); internet and network activity information (usage data, app interactions); and inferences drawn from this information.
14.3 Your CCPA/CPRA Rights. California residents have the right to: know what personal information we collect, use, disclose, and sell; delete personal information we have collected (subject to certain exceptions); correct inaccurate personal information; opt out of the sale or sharing of personal information (we do not sell your data); limit our use of sensitive personal information; and be free from discrimination for exercising these rights.
14.4 Exercising California Rights. To exercise your California privacy rights, please submit a verifiable consumer request by contacting us at service@dona.ink. We will respond to verifiable requests within 45 days, with the possibility of a 45-day extension with prior notice.
14.5 Shine the Light. California Civil Code Section 1798.83 permits California residents to request certain information about our disclosure of personal information to third parties for their direct marketing purposes. We do not share personal information with third parties for their own direct marketing purposes.
15. European Economic Area and UK - GDPR Rights
15.1 Applicability. This section applies to users in the European Economic Area (EEA) and the United Kingdom (UK) and supplements the rest of this Privacy Policy. We process your personal data in accordance with the General Data Protection Regulation (GDPR) and, where applicable, the UK GDPR.
15.2 Data Controller. For the purposes of the GDPR, Dona acts as the data controller of your personal information. Our contact details for data protection inquiries are: service@dona.ink.
15.3 Your GDPR Rights. In addition to the rights described in Clause 13, EEA and UK users have the right to: lodge a complaint with a supervisory authority (e.g., your local Data Protection Authority or the UK Information Commissioner's Office); and not be subject to automated decision- making, including profiling, that produces legal or similarly significant effects on you.
15.4 Data Protection Officer. If required by applicable law, we will appoint a Data Protection Officer (DPO) and publish their contact information in accordance with GDPR requirements. In the meantime, all data protection inquiries can be directed to service@dona.ink.
16. International Data Transfers
16.1 Global Operations. Dona operates globally, and your personal data may be transferred to, stored, and processed in countries other than your country of residence, including countries that may not provide the same level of data protection as your home jurisdiction.
16.2 Transfer Safeguards. Where we transfer personal data from the EEA, UK, or other regulated jurisdictions to countries not recognized as providing an adequate level of protection, we implement appropriate safeguards, including: Standard Contractual Clauses (SCCs) approved by the European Commission or the UK ICO; binding corporate rules where applicable; or other transfer mechanisms recognized under applicable data protection law.
16.3 Data Residency. We make reasonable efforts to store certain categories of user data on servers located in the user's geographic region where required by applicable law. Where data must be transferred internationally, we ensure appropriate protections are in place.
16.4 Inquiries About Transfers. If you would like more information about the specific safeguards applied to your data transfers, please contact us at service@dona.ink.
17. Cookies and Similar Tracking Technologies
17.1 Use of Cookies and Tracking. Our application and associated web services may use cookies, mobile analytics SDKs, and similar tracking technologies to collect and store information about your interactions with the Service. These technologies help us understand how the app is used, improve functionality, and deliver a personalized experience.
17.2 Types of Tracking Technologies. We may use: essential cookies or SDKs necessary for the Service to function; analytics cookies to measure usage and performance; and preference cookies to remember your settings and language preferences.
17.3 Mobile Advertising Identifiers. We may collect mobile advertising identifiers (such as IDFA on iOS or GAID on Android) for analytics and performance measurement purposes. You can reset or limit ad tracking through your device settings: iOS: Settings > Privacy & Security > Tracking; Android: Settings > Google > Ads.
17.4 Opt-Out Options. You may control certain tracking technologies through your device settings or through our in-app privacy settings. Note that disabling certain technologies may affect the functionality of some features of the Service.
18. Push Notifications and Marketing Communications
18.1 Push Notifications. With your permission, we may send push notifications to your device to inform you of: daily check-in reminders; community activity on your posts; milestone achievements and streak alerts; new features and app updates; and promotional offers or token bonuses.
18.2 Managing Push Notifications. You may opt out of push notifications at any time by: adjusting notification permissions in your device settings; or updating your notification preferences within the Dona app settings. Note that opting out of promotional notifications will not affect service- related notifications (such as security alerts).
18.3 Email Communications. If you have provided us with your email address, we may send you service-related emails, account alerts, and (with your consent) promotional newsletters. You may unsubscribe from promotional emails at any time by clicking the "unsubscribe" link in any such email, or by contacting us at service@dona.ink.
19. Community Standards and Content Moderation
19.1 Community Standards. Dona is committed to fostering a safe, respectful, and inclusive community for language learners worldwide. All users are expected to adhere to our Community Guidelines when creating, sharing, and engaging with content on the platform.
19.2 Automated Moderation. We use automated systems to screen UGC for policy violations, including prohibited content categories such as hate speech, harassment, CSAM, and spam. These systems may flag content for review or remove it automatically in high-confidence cases.
19.3 Human Review. Content flagged by automated systems or reported by users is reviewed by our trained moderation team. Moderators may review audio recordings, text content, and user reports to enforce our Community Guidelines.
19.4 Appeals Process. If you believe that your content was removed or your account was actioned in error, you may submit an appeal by contacting service@dona.ink with the relevant account and content details. We will review all appeals and provide a response within a reasonable timeframe.
19.5 Moderation Data Handling. Information collected during the moderation process (including flagged content, moderation actions, and appeal correspondence) is treated as personal data and handled in accordance with this Privacy Policy. It is retained for as long as necessary to fulfill safety and compliance obligations.
20. Progress Tracking and Learning Data
20.1 What We Track. Dona records and analyzes the following to power your progress experience: dates and completion status of your daily check-ins; streak history and longest streak records; total number of AI coaching sessions completed; community engagement metrics (posts published, comments made); and historical audio recordings sorted by date.
20.2 How Progress Data Is Used. Your progress data is used exclusively to: display your personal learning timeline within the app; send you milestone congratulations and streak alerts; generate aggregated product analytics (in de-identified form); and inform AI coaching personalization where applicable.
20.3 Accessing Your Progress History. All progress history is accessible within your in-app profile and progress dashboard. You may request an export of your progress data by contacting service@dona.ink.
20.4 Deletion of Progress Data. Your progress history will be deleted along with your account upon an account deletion request. Individual recordings may be deleted at any time through the in-app content management tools.
21. Account Suspension and Termination
21.1 Voluntary Account Closure. You may close your Dona account at any time through the in-app account settings. Upon closure, your account will be deactivated, your profile will be removed from public view, and your personal data will be deleted in accordance with Clause 10.
21.2 Involuntary Suspension or Termination. We reserve the right to suspend or permanently terminate your account without prior notice if we determine, in our sole discretion, that you have: violated our Terms of Service or Community Guidelines; engaged in fraudulent activity or abuse of the token system; uploaded content that violates applicable law or our CSAE policy; or created a security risk for the platform or other users.
21.3 Data Following Termination. Following account termination, we will handle your data in accordance with the retention schedules outlined in Clause 10. Data required for legal compliance purposes may be retained beyond account closure as permitted by applicable law.
22. Dispute Resolution and Governing Law
22.1 Informal Resolution. We encourage users to contact us first to resolve any privacy-related concerns informally. Please contact our team at service@dona.ink with the details of your concern, and we will make reasonable efforts to address it promptly.
22.2 Regulatory Complaints. If you are not satisfied with our response to a privacy concern, you have the right to lodge a complaint with the relevant supervisory authority in your jurisdiction. EEA users may contact their national Data Protection Authority; UK users may contact the Information Commissioner's Office (ICO); US users may have rights under applicable state privacy laws.
22.3 Governing Law. This Privacy Policy shall be governed by and construed in accordance with applicable data protection laws. Where different laws apply in different jurisdictions, we will comply with the applicable laws of each relevant jurisdiction.
23. Changes to This Privacy Policy
23.1 Right to Update. We reserve the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, applicable laws, or the features and functions of the Service. The updated policy will always be accessible within the Dona application and on our official website.
23.2 Notification of Material Changes. When we make material changes to this Privacy Policy, we will provide advance notice to users by: sending a notification through the app at least 14 days before the changes take effect; sending an email notification to your registered email address where required by law; and displaying a prominent in-app banner highlighting the nature of the changes.
23.3 Continued Use as Acceptance. Your continued use of Dona following the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree to the updated policy, you must discontinue use of the Service and may request account deletion.
23.4 Policy Version History. We maintain a record of previous versions of this Privacy Policy. If you would like to review a prior version, please contact us at service@dona.ink.
24. Contact Us
24.1 Privacy Inquiries. If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data, please contact our Privacy Team:
• Email: service@dona.ink
• App Name: Dona
• Support Portal: Available within the Dona application under Settings > Help & Support
24.2 Response Commitment. We are committed to responding to all privacy inquiries within 5 business days. For verifiable consumer requests under applicable privacy laws (e.g., CCPA, GDPR), we will respond within the timeframes required by those laws.
24.3 Language. This Privacy Policy is provided in English. If a translated version of this Policy conflicts with the English version, the English version shall prevail to the extent permitted by applicable law.
Last Updated: May 25, 2026 | Dona - service@dona.ink