DRAFT — not legally reviewed
This document is a working draft prepared for legal review. It is not an approved or binding version. Items in [brackets] must be confirmed by the owner.
Privacy Policy
Version: draft · Last updated: [PLACEHOLDER – date of approval]
1. Who is responsible
[PLACEHOLDER – legal entity name], [PLACEHOLDER – registered address]. Contact for privacy questions: [PLACEHOLDER – privacy email]. Grievance officer: [PLACEHOLDER – name and contact].
2. What we collect
Without an account: nothing is stored on our servers. Your profile, scores, tips and saved words stay in your browser on this device.
With an account: your email address, and the learning data you create — display name, help language, goal, self-described level, interests, chosen tutor and accent, weekly and daily goals, starting level, session scores (0–10) with short notes and one tip, level-check scores, and saved vocabulary.
We do not collect your contacts, location, or payment details today.
3. Voice processing
When you tap to talk, the recording is sent to an AI speech service to turn it into text. The recording and the text are used only for that conversation turn and are not saved by us.
We do not use your voice to identify you, and we do not infer emotions or personality from it.
Retention by the AI service provider: [PLACEHOLDER – provider name and its retention terms].
4. How we use your data
To run your lessons, show your progress, keep it in step across your devices, and improve the service in aggregate. [PLACEHOLDER – confirm whether data is used for model training — current intention: no].
5. Who we share it with
Service providers who host the app, store account data and run AI speech and text features, only as needed to provide the service: [PLACEHOLDER – list of processors and their countries]. We do not sell your data.
6. How long we keep it
Account data is kept while your account is open. When you delete your account, your learning data and login are deleted immediately from the live database; backups are cleared within [PLACEHOLDER – backup retention period].
7. Your choices and rights
From My account you can download all your data as a file and delete your account. You can also delete progress on a device from My sessions. Other requests: [PLACEHOLDER – privacy email]. Rights under applicable law: [PLACEHOLDER – to be drafted by counsel, e.g. India's Digital Personal Data Protection Act].
8. Children
The service is for adults (18+). We do not knowingly create accounts for children. If you believe a child has created an account, contact us and we will delete it. Any future service for school learners will require verifiable guardian consent before an account is created.
9. Security
Account data is protected so that each signed-in person can read and change only their own records. No method is perfectly secure; [PLACEHOLDER – breach notification commitment].
10. Changes
We will post changes here and tell account holders about important ones. [PLACEHOLDER – notice method].