Terms of Service for Twalkie

Last Updated: July 10, 2026

1. Acceptance of Terms

Welcome! These Terms of Service ("Terms") constitute a legally binding agreement between you and Memiri Srl ("we", "our", or "us"), an Italian single-member company and the publisher of the Twalkie app, with registered office at Via Giovanni Arcangeli, 2 — 56124 Pisa (PI) — Italy, VAT and tax number 02545410504, PEC memirisrl@pec.it, regarding your use of the Twalkie Italian language learning application and related app services (collectively, the "Services").

During onboarding, the independent user or the parent or legal guardian responsible for supervised child use must review these Terms and the Privacy Policy, agree to these Terms, and acknowledge receipt of the Privacy Policy before continuing. If you do not agree to these Terms, do not use our Services.

2. Description of Service

Twalkie is an educational mobile application that provides Italian language learning through:

Interactive lessons and exercises
Grammar explanations and vocabulary building
Audio-based learning materials
Progress tracking and personalized learning paths
Gamification elements (steps, rewards, journey unlocks)
Optional subscription features for enhanced content

3. Eligibility

Independent Use

You must meet the minimum age required to independently use and control an online account in your jurisdiction. In Italy, the age of digital consent is 14. A user who meets the applicable minimum age but has not reached the age of majority must have any parental or guardian authorization required by local law.

Supervised Child Use

A child below the applicable minimum age may use Twalkie only when all of the following are true:

A parent or legal guardian personally reviews the legal documents, accepts these Terms on the child's behalf, and acknowledges receipt of the Privacy Policy.
The parent or guardian creates or controls the account and directly supervises the child's use.
The parent or guardian provides any authorization required by applicable law and remains responsible for account activity.
Any additional age-assurance or verifiable-parental-consent requirement imposed by local law has been completed. Where Twalkie does not yet provide a legally required verification method, the child may not use the online features that require it.

The single onboarding confirmation requires the person accepting to confirm either that they are eligible to use Twalkie independently or that they are a parent or legal guardian accepting for a supervised child. We record the acceptance time, document versions, and language, but not which of those two alternatives applied. A parent or guardian may contact us at dpo@memiri.it to exercise privacy rights concerning the supervised child's data.

Account Responsibility

You are responsible for maintaining the confidentiality of your account credentials.
You are responsible for all activities that occur under your account.
You must notify us immediately of any unauthorized use of your account.

4. User Accounts

Account Types

Twalkie offers two account types:

Guest Account: Twalkie creates a temporary Firebase Anonymous Authentication account so the app can securely access required backend services. Learning progress remains local while you use Twalkie as a guest, but the anonymous account identifier, network metadata, and app-integrity data are processed by Firebase as described in the Privacy Policy.
Signed-In Account (Sign in with Apple): Provides cloud synchronization, cross-device access, and subscription features.

Account Linking

When you sign in with Apple, we link your Apple credential to your existing anonymous account when possible.
If your Apple credential is already linked to another account, we will prompt you to choose which account to keep.
We are not responsible for data loss if you choose to switch to a different account.

Account Termination by User

You may delete your account at any time. Upon account deletion:

Your personal data will be deleted within 30 days.
Local data will be removed from your device immediately.
Some transaction records may be retained as required by law.
Active subscriptions must be canceled separately through the Apple App Store.

5. Subscriptions and Payments

Subscription Terms

Subscriptions can be purchased only through the Apple App Store In-App Purchase system.
Subscription pricing, duration, and features are displayed in the app before purchase.
Subscriptions automatically renew unless canceled at least 24 hours before the end of the current period.
Your Apple account will be charged for renewal within 24 hours before the current period ends.

Billing

All subscription purchases and payments are initiated and processed only through the Apple App Store.
Apple's payment terms and conditions apply to all purchases.
We do not offer, process, or accept subscription purchases through the Website or any direct payment channel.
We do not directly process or store your payment information.
Prices may vary by region. Apple manages price-change notices and, where required, requests subscriber consent under the rules that apply to the relevant App Store storefront. If you do not accept a price change, you may manage or cancel the subscription through your Apple account before the higher price applies.

Refunds

Refund requests must be submitted to Apple through the App Store.
We do not control Apple's refund policies.
Refund eligibility is determined by Apple in accordance with their terms.

Cancellation

To cancel your subscription:

Open the Settings app on your iOS device
Tap your name at the top
Tap "Subscriptions"
Select Twalkie and tap "Cancel Subscription"

Cancellation takes effect at the end of your current billing period. You will retain access to subscription features until then.

Free Access Before Subscription

Twalkie may make selected lessons, journeys, exercises, or features available without an active subscription.
This free access is provided so users can try the app before subscribing through the Apple App Store and may change over time.
Free access does not start a subscription, does not automatically convert into a paid subscription, and does not require cancellation.
Subscriber-only content requires an active subscription.

5a. Statutory Cancellation and Withdrawal Rights

Consumers may have mandatory cancellation, withdrawal, refund, or conformity rights under the law that applies to them. Nothing in these Terms limits those rights.

Because subscriptions are offered and billed only through the Apple App Store, Apple receives the payment and administers App Store cancellation, withdrawal, and refund requests through its purchase-support channels. Memiri Srl cannot issue a refund to the original App Store payment method directly. You may contact us at dpo@memiri.it about the Twalkie service, but submitting a message to us does not replace any request that must be filed with Apple within an applicable statutory deadline.

Whether a right of withdrawal exists, how long it lasts, and whether any exception applies depend on the type of digital contract, the applicable jurisdiction, and the information and consent collected in the relevant purchase flow. We do not treat the start of a Twalkie subscription, by itself, as a waiver of rights that cannot lawfully be waived.

6. Acceptable Use Policy

Permitted Use

You may use Twalkie solely for:

Personal, non-commercial language learning
Educational purposes
Lawful activities in compliance with these Terms

Prohibited Activities

You agree NOT to:

Violate Laws: Use the app for any illegal purpose or in violation of any applicable laws.
Infringe Rights: Violate intellectual property rights, privacy rights, or other rights of any third party.
Circumvent Controls: Attempt to bypass subscription checks, content locks, or other access controls.
Reverse Engineer: Decompile, disassemble, or reverse engineer the app or its content.
Distribute Content: Copy, redistribute, or publicly display content from the app without authorization.
Automated Access: Use bots, scrapers, or automated tools to access the app.
Interfere with Service: Interfere with or disrupt the app's servers, networks, or infrastructure.
AI Training & Scraping: Use automated programs, bots, or scraping tools to extract app content, or use any app content or data to train, develop, or fine-tune any artificial intelligence or machine learning models.
Impersonate: Impersonate any person or entity or misrepresent your affiliation.
Upload Harmful Content: Upload viruses, malware, or other harmful code.
Share Accounts: Share your account credentials or allow others to access your account.

Enforcement

We reserve the right to:

Investigate suspected violations of these Terms
Suspend or terminate accounts that violate these Terms
Remove content that violates these Terms
Report illegal activity to law enforcement
Take legal action against violators

7. Intellectual Property Rights

Our Rights

All content, features, and functionality of Twalkie, including but not limited to:

Lesson content, exercises, and audio materials
Text, graphics, images, and user interface design
Software code, databases, and functionality
Trademarks, service marks, and logos

are owned by Memiri Srl or our licensors and are protected by copyright, trademark, patent, trade secret, and other intellectual property laws.

Software and Content Use

The license to download and use the Twalkie software is provided under the Apple Standard EULA referenced in Section 17. Subject to that license and these Terms, you may use Twalkie's educational content for personal, non-commercial language learning.

You may not:

Resell or make commercial use of the app or its content
Copy, reproduce, or redistribute app content
Create derivative works based on the app
Use the app for competitive purposes

User Content

You retain ownership of any content you create through the app (e.g., exercise responses).
By using the app, you grant us a license to store and process your responses solely for providing the service.
We do not sell your responses or share them for advertising or third-party marketing. When cloud sync is enabled, contracted service providers such as Firebase/Google process progress data on our behalf solely to provide, secure, and support Twalkie, as described in the Privacy Policy.

8. Content and Features

Content Availability

We strive to provide accurate, high-quality educational content.
We may update, modify, or remove content for the valid reasons and with the safeguards described in Section 13.
Some content may be marked as "subscriber only" and requires an active subscription.
We do not guarantee that content will always be available or error-free.

Visual Content

Images and other visual materials shown in Twalkie, including those used in journeys, lessons, exercises, maps, or narrative content, are provided strictly for informational, educational, and illustrative purposes. They may be stylized, simplified, generated, edited, or otherwise adapted, and may not correspond to an exact or current representation of real places, objects, routes, environments, people, events, or conditions. You should not rely on visual content in Twalkie as factual, geographic, travel, safety, historical, or professional information.

Third-Party Content

The app may contain links to third-party resources.
We are not responsible for third-party content, privacy practices, or terms.
Your use of third-party services is at your own risk.

9. Service Expectations and Statutory Guarantees

We use reasonable care to provide Twalkie and maintain its educational content. We do not promise that the service will always be uninterrupted or error-free, or that using Twalkie will produce a particular learning outcome.

If you are a consumer, you retain all mandatory legal guarantees and remedies that apply to digital content and digital services, including rights relating to conformity, security updates, and remedies for non-conforming service. Nothing in these Terms excludes a warranty, guarantee, or remedy that cannot lawfully be excluded.

10. Limitation of Liability

Nothing in these Terms excludes or limits liability where doing so is prohibited by law, including liability for fraud, willful misconduct (dolo), gross negligence (colpa grave), death or personal injury caused by negligence, breach of mandatory consumer rights, or unlawful processing of personal data.

Subject to those mandatory rules, each party is responsible for losses that are a reasonably foreseeable consequence of its breach of these Terms. We are not responsible for losses caused solely by circumstances outside our reasonable control, by unauthorized use resulting from your failure to protect account credentials, or by third-party services that we do not control, except where applicable law provides otherwise.

Twalkie is provided for personal educational use. We are not responsible for business losses arising from consumer use of the service.

11. Responsibility for Misuse

You are responsible for your unlawful or deliberately abusive use of Twalkie and for direct losses you cause by intentionally violating these Terms or the rights of another person, to the extent permitted by applicable law. This section does not create an unlimited indemnity and does not reduce any consumer defense or remedy available under mandatory law.

12. Data and Privacy

Your privacy is important to us. Our Privacy Policy is a transparency notice describing our collection and use of personal information. It does not become part of this contract merely because it is linked or acknowledged during onboarding.

Key privacy points:

We use an offline-first architecture with optional cloud sync
We do not include any analytics SDKs for behavioral tracking
We comply with GDPR and other data protection laws
You have rights to access, delete, and port your data

Please review our Privacy Policy for complete details.

13. Modifications to the Service

We may modify the service for valid reasons such as maintaining security or legal compliance, correcting errors, improving or adapting features, responding to technical requirements, or reflecting changes to services supplied by Apple, Firebase, or other essential providers.

Changes will not impose an additional charge outside the App Store purchase flow. We will explain material changes clearly. When a change materially and negatively affects paid access, we will provide reasonable advance notice on a durable medium where required and inform you of any right to terminate or obtain another remedy under applicable law.

14. Modifications to These Terms

We may revise these Terms for valid reasons, including changes in law, regulation, security requirements, service functionality, or our relationship with essential providers.

We will update the "Last Updated" date and provide clear in-app notice of material changes before they take effect. Where applicable law or the nature of the change requires agreement, we will request express acceptance. Mere silence will not be treated as acceptance where express consent is required. If you do not agree, you may stop using Twalkie and delete your account before the change takes effect, without losing any mandatory rights or remedies.

15. Termination

Termination by You

You may stop using the app at any time and delete your account through the app settings.

Termination by Us

We may suspend or terminate access when:

You materially or repeatedly violate these Terms and, where the violation can be remedied, do not remedy it after reasonable notice.
Suspension is reasonably necessary to address fraud, abuse, a security threat, or harm to other users or the service.
We are required to do so by law or by a competent authority.
We discontinue Twalkie for a valid business or technical reason, in which case we will provide reasonable advance notice where practicable and preserve any mandatory consumer remedies.

Immediate action without prior notice is limited to urgent security, fraud, safety, or legal circumstances. We will explain the reason unless the law or a legitimate security need prevents us from doing so.

Upon termination:

Your license to use the app ends immediately
You must stop using the app and delete it from your devices
Provisions that by their nature should survive termination, including intellectual-property, responsibility, and dispute provisions, remain in effect
You remain responsible for any charges incurred before termination

16. Governing Law and Jurisdiction

Governing Law

These Terms are governed by the laws of the Republic of Italy, excluding its conflict of laws provisions. The mandatory consumer protection provisions of the law of your country of habitual residence — i.e. those provisions that cannot be derogated from by contract — shall remain unaffected (fatti salvi i diritti inderogabili previsti dalla legge del paese di residenza dell'utente).

Dispute Resolution

We always prefer to resolve disputes amicably. If you have a concern, please contact us first at dpo@memiri.it. We will make every reasonable effort to resolve the issue in good faith before any formal proceedings are considered.

If you are a consumer, disputes may be brought before the courts competent under the mandatory consumer-protection rules that apply to you. For consumers resident or domiciled in Italy, the competent court is the court of the consumer's residence or elected domicile where Italian consumer law so provides. The courts of Pisa, Italy, have jurisdiction only where the user is not acting as a consumer or where that forum is otherwise validly agreed after a dispute arises.

Alternative Dispute Resolution

The European Online Dispute Resolution (ODR) platform was discontinued on 20 July 2025. Consumers in the European Union may still have access to out-of-court consumer dispute resolution bodies in their country where applicable.

Information about consumer redress tools and dispute resolution bodies in the EU is available from the European Commission at:

https://consumer-redress.ec.europa.eu/dispute-resolution-bodies

Please note that, unless required by mandatory law, we are not obligated to participate in proceedings before a consumer alternative dispute resolution body and do not commit to doing so.

European Economic Area Users

If you are a consumer in the European Economic Area, nothing in these Terms affects your rights under applicable EU consumer protection law, including your right to bring legal proceedings before the courts of your country of habitual residence.

United Kingdom Users

If you are a consumer in the United Kingdom, nothing in these Terms limits your rights under the Consumer Rights Act 2015 or other applicable UK consumer protection legislation. You retain the right to bring proceedings before the courts of England and Wales, Scotland, or Northern Ireland.

United States and Canada Users

If your habitual residence is in the United States or Canada, these Terms and any dispute arising from them shall be governed by the laws of the Republic of Italy. You may bring legal proceedings in the courts of Pisa, Italy, or — to the extent required by the mandatory consumer protection laws of your state or province — before the competent courts of your place of residence.

17. General Provisions

Entire Agreement

These Terms govern the Twalkie service and supersede prior service terms between you and Memiri Srl. The Privacy Policy is a transparency notice describing personal-data processing; it is not made a contract merely by being referenced in these Terms. The Apple Standard EULA separately governs the software license.

Severability

If any provision of these Terms is found to be invalid or unenforceable, the remaining provisions will remain in full force and effect.

No Waiver

Our failure to enforce any right or provision of these Terms does not constitute a waiver of that right or provision.

Assignment

You may not assign or transfer your account in a way that compromises account security or another person's rights. We may transfer these Terms to an affiliate or successor as part of a reorganization, merger, or transfer of the Twalkie service, provided that the transfer does not reduce mandatory consumer guarantees. We will notify you when required by law.

Force Majeure

We are not liable for any failure to perform due to circumstances beyond our reasonable control, including natural disasters, war, terrorism, riots, embargoes, acts of civil or military authorities, fire, floods, accidents, pandemics, network infrastructure failures, strikes, or shortages of transportation facilities, fuel, energy, labor, or materials.

Language

These Terms are provided in English and Italian. Neither version is intended to reduce mandatory consumer rights. If wording is ambiguous, the interpretation most favorable to the consumer applies where required by law.

Contact for Legal Notices

Legal notices to Memiri Srl should be sent to:

Email: dpo@memiri.it

PEC: memirisrl@pec.it

Mailing Address: Via Giovanni Arcangeli, 2 — 56124 Pisa (PI) — Italy

Apple Standard EULA

Twalkie is distributed through the Apple App Store. The license to download and use the Twalkie software is governed by Apple's Standard Licensed Application End User License Agreement (the "Apple Standard EULA"), unless Apple presents another applicable license in the App Store purchase flow. These Terms govern the Twalkie service, accounts, content, and our relationship with you. If these Terms conflict with the Apple Standard EULA on the scope or use of the software license, the Apple Standard EULA controls for that issue. Apple is not responsible for providing Twalkie support; service questions should be directed to Memiri Srl.

18. Acknowledgment

BY CONFIRMING AGREEMENT DURING ONBOARDING, YOU ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTOOD THESE TERMS AND AGREE TO THEM FOR YOURSELF OR, IF YOU ARE A PARENT OR LEGAL GUARDIAN USING THE SUPERVISED-CHILD OPTION, ON BEHALF OF THE CHILD YOU SUPERVISE. IF YOU DO NOT AGREE, DO NOT USE THE APP.