Privacy and Cookie Policy — Spica (Lingua.space)
Last updated: 8 October 2026
This English version is provided for information only. The French version prevails in case of any discrepancy.
The site's legal notice (publisher, host) is available on the "Legal notice" page.
The purpose of this privacy policy is to explain how personal data concerning you (the "Personal Data") is collected, processed and stored by the association LINGUA.SPACE, which operates the Spica project ("Spica" or "we"), in its capacity as data controller.
Spica is a declared association, registered under RNA number W751268479, with its registered office at 1 Villa Guibert, 75016 Paris. For any question relating to your Personal Data, you may write to us at contact@spicaclub.com.
Spica undertakes to process your Personal Data in compliance with applicable laws and regulations, in particular Regulation (EU) 2016/679 of 27 April 2016 (the "GDPR") and Law No. 78-17 of 6 January 1978 on information technology, data files and civil liberties (together, the "Applicable Regulations").
We may amend this policy at any time, in particular to reflect changes to our services or to the Applicable Regulations. You will be notified of any material change by any appropriate means.
1. Who does this policy apply to?
It covers the processing of the Personal Data of:
- visitors to the spicaclub.com website and the app.spicaclub.com platform (the "Platform");
- prospects, in particular people who contact us, request a Pitch Check or reserve a place;
- customers and participants in our services: Conversations, challenges, programmes (including "Pitch Perfect — Web Summit Edition"), one-to-one coaching and subscriptions;
- members of our online communities.
Our services are reserved for adults. We do not knowingly collect data concerning minors.
2. What processing do we carry out?
The tables below summarise, for each processing operation, the data subjects, the purposes, the data processed, the legal basis and the retention period.
2.1. Prospects and community
| Processing | Data subjects | Purposes | Data | Legal basis | Retention period |
|---|---|---|---|---|---|
| Marketing to individuals (newsletter, invitations) | Individual prospects | Responding to requests, sending information about Spica, offering a trial session or a subscription | Surname, first name, email address, level, history of exchanges | Consent (email, SMS) | 3 years after the last active contact |
| Marketing to professionals | Founders, executives and professionals, in particular from startups exhibiting at events (for example Web Summit), identified via public directories | Presenting our services tailored to entrepreneurs and their teams | Surname, first name, business email address, job title, company, source of the data, history of exchanges | Legitimate interest (developing our activities with entrepreneurs). You are informed of the source of your data in the first message and may object at any time | 3 years after the last active contact |
| Pitch Check (free feedback on a pitch) | People who send us their pitch, via the site's recorder or by WhatsApp | Listening to and transcribing your pitch, sending you personalised feedback, communicating with you | Phone number, name, voice recording or text of the pitch, transcript, information about your project and your participation in an event, exchanges | Pre-contractual steps taken at your request | Recording and transcript: deleted no later than 30 days after the feedback is sent. Exchanges: 3 years after the last active contact |
| Reserving a place (form without payment) | People who reserve a place on a programme | Organising your participation, getting back in touch with you, sending you the payment link | Surname, first name, email, WhatsApp number (optional), startup, website, time-slot preferences, goals, need for an invoice, option chosen, acceptance of the general terms of sale and, where applicable, request for early performance (with the date and time) | Pre-contractual steps taken at your request | 3 years after the last active contact if no order is placed; duration of the contractual relationship if an order is placed |
| Community and free events (WhatsApp or Telegram groups, invitations) | Members of our communities and participants in our free events | Running the community, sharing information, inviting people to free events | Name or pseudonym, number or identifier, content posted, participation metadata | Legitimate interest (running an international learning community; you may leave it at any time) | Duration of participation in the community |
2.2. Platform users and participants
| Processing | Data subjects | Purposes | Data | Legal basis | Retention period |
|---|---|---|---|---|---|
| Creating and managing the Account | Platform users | Creating and securing your Account, enabling you to book sessions and use your Credits | Email, password (encrypted) or your Google account information, profile, answers to the onboarding questionnaire, bookings, Credits history | Performance of the contract | Duration of the Account; deletion when it is closed or after 3 years of inactivity |
| Initial assessment ("Stella" assistant) | Platform users | Assessing your level, setting your priorities, directing you to suitable sessions | Recorded spoken answers (audio files), answers to reading and listening comprehension tests, results, coach's assessment | Performance of the contract or pre-contractual steps taken at your request | Results: duration of the Account. Audio recordings: duration of the Account |
| Participation in sessions and learning follow-up (Conversations, challenges, programmes, coaching) | Participants | Organising sessions, recording and transcribing exchanges, preparing your personalised feedback, tracking your progress, compiling your Pitch Kit | Identity, level, attendance, session recordings, transcripts, voice messages sent between sessions, assessments, coach's comments and feedback | Performance of the contract | Session recordings and voice messages: 30 days after the corresponding feedback is sent. "Before / after" recordings for a programme: 3 months after the end of the programme. Transcripts, assessments and feedback: duration of the contractual relationship |
| Payment, invoicing and accounting | Customers | Collecting payment, issuing invoices, keeping the accounts | Identity, email, company and billing address where applicable, order, amounts, transaction references (bank card data is processed solely by our payment provider) | Performance of the contract and legal obligation | 10 years for accounting records |
| Service emails and notifications | Users and customers | Sending you confirmations, session reminders, information about your Credits and service-related messages | Email, first name, message content | Performance of the contract | Duration of the contractual relationship |
| Testimonials | Participants who agree | Publishing your review or an excerpt showing your progress | First name, job title or city, text, where applicable an audio excerpt | Consent | Until you withdraw your consent |
| Complaints, withdrawal and exercise of your rights | Customers, users, prospects | Handling your requests and keeping proof that they have been handled | Identity, contact details, content of the request, response given | Legal obligation | Time taken to handle the request, then archiving for the applicable limitation period |
3. Voice recordings and speaker separation
Group sessions take place on a videoconferencing tool and are recorded; you are informed of this before placing your order and at the start of each session. The recordings are transcribed automatically in order to prepare your personalised feedback.
To attribute each contribution to the right participant, the transcription tool automatically distinguishes between the different voices within a single recording (for example "Speaker A", "Speaker B"), without identifying them. The coach then manually attributes each contribution to the participant concerned. No voiceprint is stored, or used to identify you from one session to another or outside our services.
One-to-one sessions may take place without being recorded, on simple request made no later than the start of the session.
4. Artificial intelligence
We use artificial intelligence tools to transcribe recordings and to help us prepare learning feedback. All feedback is reviewed and approved by a coach. No decision producing legal effects concerning you, or significantly affecting you, is taken solely on the basis of automated processing.
We do not use your recordings and transcripts to train artificial intelligence models. We favour providers and settings that exclude the use of such data for training their own models.
5. Recipients and service providers
Your Personal Data is accessible only to authorised persons within Spica and, to the extent necessary, to our technical service providers, who act on our instructions:
| Service provider | Role | Data location | Safeguards for transfers outside the EU |
|---|---|---|---|
| Lovable Labs Sweden AB and its sub-processors | Hosting of the site and the Platform, database, authentication, storage of audio files, sending of service emails | European Union (database in Frankfurt, Germany); some technical sub-processors may be established outside the EU | European Commission Standard Contractual Clauses and, where applicable, Data Privacy Framework |
| Digital Samba | Videoconferencing and session recording | European Union | Not applicable |
| AssemblyAI, Inc. | Transcription of recordings | Processing via the provider's European endpoint; company established in the United States | European Commission Standard Contractual Clauses |
| Artificial intelligence assistant provider (business plan) | Assistance in preparing learning feedback | European Union or United States depending on the provider | European Commission Standard Contractual Clauses and, where applicable, Data Privacy Framework |
| Stripe Payments Europe, Limited | Online payment | European Union (Ireland); possible transfers to the United States | Data Privacy Framework and standard contractual clauses |
| Qonto (Olinda SAS) | Banking | France | Not applicable |
| Brevo (Sendinblue SAS) | Information emails | European Union | Not applicable |
| Google Ireland Limited | Booking calendar, sign-in with a Google account, email | European Union; possible transfers to the United States | Data Privacy Framework |
| WhatsApp Ireland Limited | Exchanges, community and receipt of Pitch Checks | European Union; possible transfers to the United States | Data Privacy Framework |
| Telegram | Online community (if you choose to join it) | Outside the European Union | Telegram acts as a separate data controller for its own service |
We do not sell or rent your Personal Data.
6. Retention and security
Your Personal Data is kept in the active database for the periods indicated in the tables above. At the end of these periods, it is deleted or anonymised. Where applicable, we may keep in intermediate archives the data strictly necessary (i) to comply with our legal obligations, in particular accounting obligations, and (ii) to defend our rights in the event of litigation, for the applicable limitation periods.
We implement appropriate technical and organisational measures to protect your Personal Data: access limited to authorised persons, storage of audio files in a private space specific to each user, encrypted connections and deletion of recordings at the end of the periods indicated.
7. Cookies and trackers
The site and the Platform use only trackers that are strictly necessary for their operation, which do not require your consent:
| Tracker | Purpose | Duration |
|---|---|---|
| Session token (browser local storage) | Keeping you signed in to your Account | Until you sign out |
| Selected plan and current sign-up step (local and session storage) | Resuming your sign-up or payment process where you left off | Until the end of the process or the closing of the tab |
| "sidebar_state" cookie | Remembering how the side menu is displayed | 7 days |
| Payment provider (Stripe) cookies, during payment | Securing payment and preventing fraud | In accordance with Stripe's policy |
We do not use any audience measurement tools, advertising trackers or embedded social networks. Fonts are hosted on our own servers. The booking calendar opens in a new tab on Google's website, whose privacy policy then applies. The site's forms (reservation, Pitch Check) are processed by our host, without trackers.
If we were to use trackers subject to consent in the future, we would ask for your agreement beforehand, by means of a banner allowing you to accept or refuse them just as easily.
8. Your rights
In accordance with the Applicable Regulations, you have the right to access your Personal Data, the right to rectify inaccurate data, the right to erasure under the conditions laid down by the Applicable Regulations, the right to restriction of processing, the right to object to the processing of your Personal Data (including at any time and without giving reasons, to object to direct marketing) and, where applicable, the right to portability of your Personal Data. You also have the right to set out instructions regarding what happens to your Personal Data after your death.
Where processing is based on your consent, you may withdraw it at any time, without affecting the lawfulness of processing carried out before its withdrawal.
To exercise your rights or for any question, write to us at contact@spicaclub.com or by post to LINGUA.SPACE, 1 Villa Guibert, 75016 Paris. We will respond within one month, which may be extended by two months in the case of a complex request; we will inform you of this if so.
You also have the right to lodge a complaint with the Commission nationale de l'informatique et des libertés (CNIL), 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07 — www.cnil.fr.