Italio

Privacy Policy

Version 2026-10-09, effective October 9, 2026

Earlier version: September 21, 2026

1. General Information

Italio ("the App") is a mobile application that prepares residents of Italy for the Italian-language exam required for citizenship (CILS or CELI, modulo cittadinanza, level B1) and for the exam required for the EU long-term residence permit (level A2). It is developed and published by IOCODO LLC ("we", "our", "us").

This Privacy Policy explains what information the App handles, how it is used, and the choices available to you. Italio is designed to be usable offline and does not ask you for a name, an email address or any other personal detail in order to learn.

2. Data Stored on Your Device

The App stores your learning data locally, in a database on your device. This is the primary copy and is what makes the App work offline. It includes:

• Your learning progress and spaced-repetition review schedule, meaning which words, grammar cards and exam sections you have studied and when each is due to come back
• Notes you write for yourself on a word
• Your answer history and simulation scores
• Voice recordings you make in the speaking practice, which stay on your device and are never uploaded to us or to any third party. You can delete them at any time from within the App
• In-app preferences and settings, including your interface language, sound and reminder time
• Practice reminders you choose to schedule, which the operating system holds on the device itself
• From version 1.1.6, a record of each choice you make about usage statistics and crash reports, and the decision the App takes from your app store's age signal (Sections 8 and 13). Neither is sent to us

All learning content (words, grammar cards, audio, reading and listening texts, exam guide and simulations) is bundled inside the App at install time. The App does not download lesson content while you use it.

On-device data, including your voice recordings, is removed when you uninstall the App, subject to any device backup behaviour controlled by Apple or Google.

3. Account and Authentication

Italio does not require you to create an account or sign in to learn. On first launch the App signs you in anonymously using Firebase Authentication (Google LLC), which generates a random identifier tied to your installation. That identifier carries no name, email address, password or phone number, and we cannot identify you personally from it.

From Settings you can optionally link that guest session to an Apple or Google account, so your progress follows you to a new device. Linking is never required and no lesson is locked behind it. If you choose to link:

• We receive your email address and, when the provider supplies them, your display name and, from Google, the link to your profile picture. Firebase Authentication stores them with your account.
• We never receive your password. You authenticate with Apple or Google, not with us.
• Sign in with Apple lets you hide your real address. If you do, we only ever see Apple's private relay address.
• Your email address and name are used to identify your account and restore your progress. They are not used for marketing, are not shared with anyone else, and are deleted with everything else when you delete your account (see Section 12).

4. Data Stored in Firebase Backend Services

Italio uses a small set of Firebase services operated by Google LLC, under the Firebase project italio-app:

• Firebase Authentication: issues the anonymous identifier described above, and stores your email address and display name if you choose to link an Apple or Google account.
• Cloud Firestore (EU region): stores a backup of your review schedule, keyed to your identifier, so your progress survives a reinstall or a new device. For each word and grammar card, the backup holds when you last reviewed it, when it is due again, how many times you reviewed and forgot it, how well you know it and whether you have typed it yourself, plus any note you wrote on it. Your answer history, simulation scores and voice recordings are not in it and stay on your device. The same database holds the content reports described in Section 5, the record described in Section 6 and, only if we give you the full path as a gift, a record of that gift.
• Firebase App Check: verifies that requests come from a genuine Italio installation, using device attestation (App Attest on iOS, Play Integrity on Android).
• Firebase Remote Config: lets us change small pieces of App configuration remotely, such as the minimum supported App version.
• Firebase Cloud Messaging: delivers the notifications described in Section 7.

The cloud backup runs in the background whenever the App is online, for guests too, and is best-effort. If you are offline, or if background sync is unavailable for any reason, the App keeps working normally from the local copy on your device, which remains the source of truth.

5. Content Reports and Emails

If you report a problem with a word, grammar card, audio clip, reading text or exam question, the App sends us a short report so we can fix it. A report contains the item being reported, the type of problem, the text that was on screen, an optional note you write yourself, your interface language, the App version, the date and your identifier. It carries no name, email address or contact detail, and it is used only to correct the App's content. A request for an interface language the App does not offer yet travels the same way. Reporting is always optional.

If you write to us by email, we receive your address, the name your email shows and what you write. Our mailbox is hosted by GoDaddy, and we use Claude, an AI assistant made by Anthropic, PBC, to help us read reports and emails and prepare replies.

6. Device and Version Record

The App keeps one small record about your installation in Cloud Firestore, keyed to your identifier and written at most once a day, usually not at all. It holds:

• your App version and build number, the App's identifier, your platform and its operating system version
• when you last opened the App, recorded at most once a day
• the date you installed, the week your installation first appeared and the App version you first installed
• whether this installation has the full path, and since when

We use it for operational questions that aggregate statistics cannot answer: which build a user is actually running before we set a minimum supported version, whether a bad build has been left behind, and who has paid, so that we can help them. It carries no name, email address or contact detail, and the App never reads it back to open paid content.

7. Notifications

The Notifications from Italio switch in Settings covers two kinds of notification. Turning it off silences both.

• The daily study reminder is scheduled and held by your device's operating system at the time you pick. It is not sent from a server. The App offers it once, after a lesson. On Android versions before 13, which show notifications without asking, the reminder can be on without that offer, and you can turn it off in Settings.
• Occasional messages about the App come through Firebase Cloud Messaging. From version 1.1.6, nothing is set up for them until you ask for notifications: you turn them on, with the switch in Settings or with Turn it on when the App offers the reminder, and you allow them when your device asks. On Android versions before 13 the device does not ask, so your tap in the App is the request. Only then does Firebase create the registration token that lets your device receive these messages, and Google holds that token. The App then subscribes your device to a few shared topics: everyone, your platform, your interface language, and the week you last opened the App. That last topic lets us write to people who have not opened Italio for a while; it is split into two halves, worked out from your identifier, so we can compare people who get a message with people who do not. The App stores no notification token with your identifier.

The token is deleted, and every topic subscription with it, when you turn the switch off, when you block notifications for Italio in your device settings (the next time you open the App), when you sign out and when you delete your account. Your choice to receive notifications belongs to the phone, so after you sign out a new token is created if notifications are still on, tied to nothing from the account you left. Deleting your account also resets that choice, and no new token exists until you turn notifications on again. If you never asked for notifications and an earlier version created a token when it started, version 1.1.6 deletes it the first time it opens.

In versions before 1.1.6, the App joins the topics when it starts on Android, and a message appears once notifications are allowed for Italio; on iPhone it joins them only after you have allowed notifications. In those versions, turning the switch off unsubscribes your device from every topic.

8. Analytics, Diagnostics and Third-Party Services

The App uses two Google-provided services to understand how it is performing:

• Firebase Analytics: records usage events, for example which screen you opened or which exercise you finished, so we can see how the App is used and improve it. These events do not carry your name, email address or contact details.
• Firebase Crashlytics: collects crash and error reports if the App malfunctions, including your device model, operating system version, App version and a technical log of what the App was doing at the time. Crash reports do not include your name, email address, your recordings or what you were studying.

Google LLC runs both for us and processes the data in the United States.

When they start, and how to change it

From version 1.1.6, usage statistics and crash reports are both off when the App is installed. Where the App asks you, nothing is sent until you answer. How it asks depends on where your phone is. The App reads this from the country of your App Store or Google Play account and from your phone's time zone, never from its language, and when the two point to different places the stricter rule applies.

• European Union, Norway and Liechtenstein. The start key on the first screen states an age, such as I'm 16 or older, start. The line under it says what the key turns on, that Google Firebase keeps the data in the United States, where privacy law can differ from yours, and where to change it. That tap turns on both. The second key, Start without sharing, opens the same first lesson with both off: use it if you are under the age shown. The age is 16, or the one your country sets:
  • 13 in Belgium, Estonia, Malta, Norway, Portugal and Sweden
  • 14 in Austria, Cyprus and Spain
  • 15 in the Czech Republic, Denmark, France, Greece and Slovenia
• Switzerland, and iPhones in any place not listed here. The line under Start learning says that the tap also turns on usage statistics and crash reports, sent to Google Firebase, and where to turn them off. Tapping Start learning turns them on.
• United Kingdom. Usage statistics stay off until you turn them on in Privacy choices, which asks you to do so only if you are 13 or older. Crash reports, which describe technical faults only, are on from the first launch on Android. On iPhone they also wait for Privacy choices.
• Canada, Brazil, and iPhones in Vietnam. Both stay off until you turn them on in Privacy choices, which states the age needed to do so: 14 in Canada, 18 in Brazil and 16 in Vietnam. In Canada the screen also says that the data goes to Google Firebase in the United States, and that you can see or correct it by writing to support@iocodo.com. In Vietnam it says that usage statistics are sensitive personal data under Vietnamese law, that what you allow is sent to Google LLC in the United States, and why.
• Android phones in any other place. Both are on from the first launch, with no extra step.

Changing your mind. Open Settings, then Privacy choices. There is one switch for usage statistics and one for crash reports, and a change applies at once. Every learner has these switches, except in Russia and mainland China, where the App sends neither (see Section 16). Crash reports the App kept on your phone while they were off are deleted, never sent later.

If you used Italio before version 1.1.6 and never chose whether to send usage statistics and crash reports, the App asks you once, on the Today screen: a line under the first key, the one that starts your lesson. It is not a new screen or a window to close. In the European Union, Norway and Liechtenstein the key states the minimum age your country's law sets, and a second key, Start without sharing, opens the same lesson without sending anything. On iPhone in other countries and in Switzerland, tapping the key is your consent, and the line says so. A tap counts as consent only if the whole line is on screen at that moment; otherwise the lesson starts anyway and the question stays for next time. In the United Kingdom (statistics only), Canada, Brazil and on iPhone in Vietnam the line does not appear: everything stays off until you turn it on. It does not appear in installs that keep all data on the phone either. Once you answer, with either key or in the settings, the question does not come back. You can change your choice at any time in Settings, under Privacy choices.

The App keeps a record of each choice on your phone: what you chose and when, the version of the wording you saw, the App version, the place rule that applied, how you answered and, with a yes on the first screen, the age you confirmed. This record is not sent to us.

In versions before 1.1.6, both start when the App opens and the App has no switch for them. To object to them in those versions, write to us at the address in Section 18.

During normal operation, the App communicates only with the following third-party services:

• Firebase Authentication (Google LLC): the anonymous identifier, plus email address and display name if you link an account
• Sign in with Apple (Apple Inc.): optional account linking
• Google Sign-In (Google LLC): optional account linking
• Cloud Firestore, EU region (Google LLC): the backup described in Section 4, the record in Section 6 and content reports
• Firebase App Check (Google LLC): request integrity verification
• Firebase Remote Config (Google LLC): remote App configuration
• Firebase Cloud Messaging (Google LLC): notification delivery
• Firebase Analytics (Google LLC): usage analytics
• Firebase Crashlytics (Google LLC): crash and error diagnostics
• Apple App Store (Apple Inc.) and Google Play (Google LLC): purchases and receipt validation

This version of the App requests access to your microphone, used only to record your own voice during speaking practice. Those recordings stay on your device, are never uploaded to us or to any third party, and you can delete them at any time from within the App. The App requests no access to your camera, contacts, photos or location.

9. Payments and Purchases

Italio is free to start, and the A1 level is free in full. An optional one-time purchase opens every level from A2 to C1 and the remaining exam simulations. There is no subscription. All payments are processed entirely by the Apple App Store or Google Play. We do not operate our own payment system.

We never receive, see or store your card number, billing address or any other payment detail. The store reports back only whether a valid purchase exists, so the App can open the paid content. After a reinstall, the App asks the store again when you tap Restore purchase. The record in Section 6 notes whether your installation has the full path. Your purchases, billing and refunds are governed by the privacy policy and terms of the store you bought from. See our Terms of Use for the purchase terms.

10. Learning Content and Attribution

Every word, grammar card, reading text, listening script, speaking prompt and exam simulation in Italio is original material, written by IOCODO LLC on the publicly available syllabus for the modulo cittadinanza and the A2 civic-integration exam. The App does not reproduce or redistribute any official exam questions.

Italio is an independent app. It is not affiliated with or endorsed by Università per Stranieri di Siena, Università per Stranieri di Perugia, Università Roma Tre, Società Dante Alighieri or the Ministero dell'Interno.

11. Data Sharing and Sale

We do not sell your data. We share it only as needed to operate the App, or where the law requires it: with the Firebase services described above, which run on Google infrastructure, and, for content reports and emails, with GoDaddy and Anthropic as described in Section 5. Nothing is shared with other learners.

Apart from these providers, we do not let other companies collect personal data about your activity over time and across other apps and websites through Italio.

12. Account Deletion and Data Retention

You can delete your account and all associated data at any time:

• In-app: open Settings, then Account, and tap Delete account, then confirm. This clears the learning data and voice recordings stored on your device, deletes your cloud backup, your content reports, the record in Section 6 and any gift record, and deletes your Firebase Authentication identity, including the email address and display name if you had linked an Apple or Google account.
• By email: write to support@iocodo.com with the subject "Italio Account Deletion". We complete the deletion within 30 days and confirm by reply.

Step-by-step instructions, including what survives deletion and why, are on the account deletion page. Any remaining copy of your data in our backend systems is removed within 30 days. Crash reports are held for up to 90 days and then deleted.

13. Children's Privacy

Italio is a general-audience education app. It is not directed at children under the age of 13, and we do not knowingly collect personal information from children. The App can be used in full without an account: nothing in it requires a name, an email address or any other personal detail, so it suits learners of any age under the supervision appropriate to their context. The optional account linking in Section 3 is a choice made by the device owner.

Your app store's age signal. From version 1.1.6, the App reads the age signal your app store offers where a law requires stores to share one with apps, as in Texas and Brazil.

• On iPhone, Apple first tells the App whether your account falls under such a law. Only then does the App ask for your age range, which Apple shares through its own screen as a band (under 13, 13 to 15, 16 to 17, or 18 and over), at most once every six months and never over the App's first screen.
• On Android, the App reads Google Play's age signal only for a Play account in the United States or Brazil. Google Play may show its own prompt before sharing it.

The App uses the signal for one purpose: to decide whether a future significant change to the App, one that the law says needs a parent's approval for a minor, must wait for that approval. Today no part of the App depends on that decision.

Only the decision is kept, on your phone, together with the date the store answered and whether it said a law applies. The age range, where it came from and any answer from a parent stay in the phone's memory while the App is open, and are never saved, logged, sent to us or used for statistics.

14. Your Rights (GDPR, CCPA and similar laws)

Depending on where you live, you may have rights over your data under laws such as the EU and UK General Data Protection Regulation or the California Consumer Privacy Act. Unless you have linked an Apple or Google account as described in Section 3, the data we hold about you is the anonymous learning data described above, so that is what most of these rights apply to. You can, at any time:

• Access, export or correct your data, using the in-app export where available, or by contacting us.
• Delete your data and your account, as described in Section 12.
• Object to or restrict what the App sends: turn off Notifications from Italio in Settings, send content reports only when you choose, and use the App without linking an account. From version 1.1.6, you can also turn off usage statistics and crash reports in Settings, under Privacy choices (Section 8). In earlier versions they have no switch, so write to us to object to them.
• Contact us with any question or request about your data, at the address in Section 18.

We do not sell personal information, and there is no "sale" or "sharing" of data to opt out of under the CCPA. If you live in Texas or in Mexico, Section 16 sets out your rights there.

15. Launch Waitlist on This Website

This section is about the Italio pages on iocodo.com, not the App. Before Italio launched, these pages had a box where you could leave your email address to hear when it came out. That box has been removed. The addresses typed into it were stored in our own Cloud Firestore database, together with the language of the page used and the address of that page. Nothing else was recorded, and no cookie or tracking identifier was attached.

We use those addresses for one thing only: a single message saying that Italio is available on the App Store and Google Play. It is not a newsletter, the list is not passed to anyone else, and it is not used for advertising. The list is deleted once that message has been sent. To be taken off it before then, write to support@iocodo.com.

16. Notices for Some Places

Texas

If you live in Texas, the Texas Data Privacy and Security Act gives you rights over your personal data. This is how they work with Italio.

What we process. The categories of personal data are the ones described in Sections 2 to 7 and 15:

• identifiers: the random user ID, installation identifiers and, if you link an Apple or Google account, your email address and name
• your learning backup: your review schedule and the notes you write
• device and App information: device model, operating system and App version, and whether you have the full path
• usage statistics, including purchases, and crash reports
• content reports and the emails you send us
• from version 1.1.6, the decision the App takes from your app store's age signal, which stays on your phone (Section 13)

We process no sensitive data. Your voice recordings stay on your device and never reach us.

Why. To run the App and back up your progress, to open the full path when you buy it, to keep the App working and fix faults, to understand how the course is used, to send the occasional message about the App, to answer your reports and emails and, from version 1.1.6, to decide from your app store's age signal whether a change to the App must wait for a parent's approval.

Who receives it. We do not sell personal data, and we do not use it for targeted advertising or for profiling that has legal or similarly significant effects. We share it only with processors that run services for us: Google LLC (Firebase), GoDaddy (our mailbox) and Anthropic, PBC (Claude).

Your rights. You can ask us to confirm whether we process your personal data and to give you access to it, to correct it, to delete it, and to send you a copy in a portable format. You can also opt out of the sale of your data, of targeted advertising and of profiling, although we do none of them.

How to ask. You do not need an account. Use any of these:

• email support@iocodo.com
• call or text +1 307 800 7271 and leave a message
• to delete everything, tap Delete account in the App, as described in Section 12

We reply within 45 days. If we need more time, we tell you why within those 45 days, and we can extend once by another 45 days. If we turn your request down, we tell you why and how to appeal.

Appeal. Reply to our answer, or write to the same address, with "Appeal" in the subject. We answer in writing within 60 days and explain our decision. If we deny your appeal, you can file a complaint with the Texas Attorney General.

Mexico

If you use Italio in Mexico, this is our privacy notice under the Ley Federal de Protección de Datos Personales en Posesión de los Particulares, in Spanish.

Russia and mainland China

From version 1.1.6, when the country of your App Store or Google Play account is Russia or mainland China, Italio keeps your progress on your phone only. It does not start the Google Firebase services listed in Section 8, so it creates no account for you, makes no online backup and sends no usage statistics or crash reports. Account linking, the backup, messages about the App and content reports are not offered there. The daily study reminder still works, because your phone holds it.

For Russia, if our servers hold a copy of your data from an earlier version, the App deletes it once and then tells you that it has.

17. Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes, we will update the version date at the top of this page. Continued use of the App after changes are posted constitutes your acceptance of the updated policy.

18. Contact

If you have questions about this Privacy Policy, please contact:

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