Privacy & Cookie Policy

Townshub Limited — Nicosia, Cyprus
Last updated: 7 October 2026

In short: we use your data to run your account, courses, community and payments. We don't sell it and we don't use it for advertising. Optional things — visitor statistics and automatic translation — only happen if you say yes. You can download or delete your data yourself from your profile.

1. Who we are

Townshub Limited (company reg. HE 481530, VAT CY60229992X), Nicosia, Cyprus, is the controller of your personal data. Contact: admin@townshub.com.

We follow the General Data Protection Regulation (EU) 2016/679 (GDPR) and the Cyprus data protection law (Law 125(I)/2018). Our supervisory authority is the Office of the Commissioner for Personal Data Protection of the Republic of Cyprus.

2. What we collect, why, and on what legal basis

DataWhyLegal basis (GDPR Art. 6)
Name, email, password (stored hashed — we can't see it), role, profile photo, bio, learning goal, location (optional)Your accountContract
Course progress, quiz results, XP, streaks, badges, project submissionsRunning your coursesContract
Posts, replies, likes, direct messagesCommunity featuresContract
Live-class video and audio, in-class chat, whiteboard, attendanceLive teachingContract
Voice recordings when you use pronunciation practice or the AI conversation tutorScoring your pronunciation and running conversation practice. Recordings go to our speech providers (section 5) and are not stored by us — we keep only your scoresContract
Billing name and address, customer and transaction IDs, invoices (we never see your card number — Stripe, Flutterwave or Apple handle payment)Billing, tax and accountingContract; legal obligation
Email address and your marketing choiceAccount emails (receipts, password resets, service notices); marketing emails only if you opted inContract; consent
Device token and reminder settings (mobile app)Lesson reminders, if you allow notificationsConsent (device permission)
Visitor statistics: pages visited, referrer, device, browser, screen size, country. Your country is worked out on our own server and your IP address is not storedImproving the platformConsent (cookie banner)
Your cookie choices, with a timestampProving what you agreed toLegal obligation
Server logs kept by our host (IP address, browser, page requested)Security and fraud preventionLegitimate interests
Which partner referred you (if any), and your payments while that referral countsPaying our affiliate partners a commission. Partners see only totals, never your name or emailLegitimate interests
Partner programme (only if you apply to be a partner): your application (name or organisation, country, website, audience, how you'll promote), partner code, earnings and payouts, and the bank account you give us for payouts (stored encrypted). If you connect Stripe, only your Stripe account id and whether it can receive payouts. For schools and organisations: the names of staff you create links for, and your page logo and welcome textReviewing your application, running the partnership and paying your commission (automatically through Stripe, Paystack or Flutterwave)Contract

We don't make decisions about you that have legal or similarly significant effects by automated means. AI-generated feedback (for example pronunciation scores or reply suggestions) is advisory, and you can ask a person to review it.

3. Mobile app permissions

4. Cookies and similar technologies

Strictly necessary (always on)

NamePurposeDuration
PHPSESSIDKeeps you signed inUntil you close the browser
lang, lang_pick, googtransThe language you chose from the menu12 months
th_consentRemembers your cookie choices12 months
theme (local storage)Light or dark modeUntil cleared

Payment pages load Stripe, which may set its own cookies to prevent fraud during the payment you started.

The iPhone app does not track you. Inside the Townshub Academy app we use only the strictly necessary cookies above. The optional categories below are switched off and cannot be turned on there, so no analytics and no automatic translation run, and we do not share data with advertisers or data brokers or link it with third-party data for advertising.

Optional (only with your consent)

CategoryWhat it doesStored on your device
AnalyticsVisitor statistics, kept on our own servers. Nothing is shared with advertisers._th_sk — a random ID in session storage, cleared when you close the tab
Analytics (affiliate referral)If you arrived through a partner's link, remembers their code so the partner gets credit if you subscribe. Partners never see who you are.th_ref — 30 days (or this visit only without consent)
Automatic translationTranslates pages into your browser's language using Google Translate. Page text and your IP address go to Google. (Choosing a language yourself from the menu works without this.)googtrans

You can change your choices at any time:

5. Who receives your data

We don't sell personal data. These providers process it on our behalf, under data processing agreements:

ProviderPurposeLocation
SupabaseDatabase, sign-in, file storageEU (Ireland)
HostingerWebsite hosting, email delivery, server logs; our live-class serverEU (Germany; live classes France)
StripeCard payments, subscriptions, invoices; payouts to partners who connect a Stripe account (Stripe Connect)EU (Ireland) / US
PaystackPayouts to partners' Nigerian bank accounts (account number, bank and holder name)Nigeria / EU
FlutterwavePayments in Africa; payouts to partners' Nigerian bank accounts (account number, bank and holder name)Nigeria / US
AppleiPhone in-app purchases and notificationsUS
Google FirebaseAndroid notificationsUS
Microsoft Azure SpeechPronunciation scoring (your voice)EU (Germany)
ElevenLabsLesson audio and the AI conversation tutor (your voice)US / EU
HeyGen (with LiveKit)AI video tutor (your voice and video during live avatar sessions)US
AnthropicThe AI features you use: the live-class assistant (@assistant), conversation practice and AI tutor, AI feedback on quiz answers, agents; also course-content tools and reply suggestionsUS
OpenAI, Perplexity, Google GeminiContent-creation tools used by instructorsUS
Bunny.netCourse video streamingEU (Slovenia)
Google TranslatePage translation — only with your consent or when you pick a languageUS
OpenStreetMap FoundationMembers map images and location lookupUK
YouTubeClass recordings, only if you press playUS

AI features. When you use the live-class assistant (@assistant), conversation practice, the AI tutor, AI feedback on quiz answers or agents, what you type (and your voice in the voice and video tutors) is sent to the AI providers listed above so they can write the reply. In the iPhone app we ask your permission first and these features stay off until you allow them; you can change this at any time in Profile > Privacy & your data.

AI replies to your public posts. Only if you turn it on in Profile > Privacy & your data (it is off by default), an automated AI assistant may reply to your public community posts. The text of the post is sent to Anthropic to write the reply, which is labelled as AI-written and is not from our instructor. We record when you turn it on or off, and you can switch it off at any time. Private messages are never read by AI.

Where data leaves the European Economic Area, we rely on the European Commission's Standard Contractual Clauses and, where the provider is certified, the EU–US Data Privacy Framework. The UK has an EU adequacy decision.

Country lookup uses IP geolocation by DB-IP, from a database stored on our own server — your IP address is not sent to DB-IP.

6. How long we keep data

DataKept for
Account, course, community and message dataUntil you delete your account (or ask us to)
Payment and invoice records7 years (Cyprus tax and accounting law); unlinked from your account if you delete it
Partner applications that were rejected or withdrawn12 months
Partner bank detailsUntil 90 days after the partnership ends and nothing is owed
Partner staff links (staff names), co-branded page text and logoUntil the partner removes them or the partnership account is deleted
Partner commission and payout records7 years (accounting); unlinked from you if you delete your account
Visitor statistics13 months
Cookie-consent records3 years
Notification send log90 days
Server logsAs kept by our host for security, then deleted

Expired data is deleted automatically every day.

7. Your rights

You have the right to access your data, download it in a portable format, correct it, have it deleted, restrict or object to processing, and withdraw consent at any time (this doesn't affect processing before you withdrew).

You can also complain to the Office of the Commissioner for Personal Data Protection, Cyprus (dataprotection.gov.cy), or to the data protection authority where you live or work.

8. Children

Townshub is for people aged 16 or over. (Cyprus law allows children from 14 to consent to online services; we chose a higher minimum.) Younger learners may use Townshub only with a parent or guardian who creates the account and agrees on their behalf. If we learn we hold a child's data without that consent, we will delete it.

9. Security

No system is perfectly secure. If a breach puts your rights at risk, we will report it to the Commissioner within 72 hours and tell you without undue delay, as GDPR Articles 33 and 34 require.

10. Changes to this policy

We'll email you about material changes at least 14 days before they take effect. The date at the top shows when the current version took effect.

11. Contact

Townshub Limited
Nicosia, Cyprus
Email: admin@townshub.com

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