Privacy Policy

1. Information We Collect

We collect information you provide directly, including:

• Account information (email, display name)
• Learning preferences (target level, English variant)
• Chat conversations with our AI tutor
• Audio recordings from speaking practice (if enabled)
• Transcripts of your spoken responses
• Learning progress and performance data

2. How We Use Your Information

We use your information to:

• Provide personalized English learning experiences
• Improve our AI tutoring capabilities
• Track your learning progress
• Analyze and improve our services
• Communicate with you about your account

3. AI and Data Processing

Our service uses artificial intelligence to provide language learning features. Your chat messages, audio recordings, and transcripts may be processed by AI systems to:

• Provide real-time conversation practice
• Analyze pronunciation and speaking patterns
• Generate personalized feedback and corrections
• Adapt content to your learning level

4. Data Retention

We retain your data as follows:

• Account information: Until you delete your account
• Learning progress: Until you delete your account
• Audio recordings: Maximum 30 days (or immediately deleted after transcription if you opt out of storage)
• Chat conversations: Until you delete your account

5. Your Rights

You have the right to:

• Access your personal data
• Export your data
• Delete your account and all associated data
• Opt out of audio recording storage
• Update your consent preferences at any time

6. Third-Party Services

We use the following third-party services to provide our platform. These services may process your data as described below:

• AI Language Models (Google Gemini, OpenAI) — Process your chat messages, writing submissions, and transcripts to provide tutoring, feedback, and corrections. Data is sent to servers in the United States and processed under their respective data processing agreements.
• ElevenLabs — Processes audio data for voice practice features including text-to-speech and speech analysis. Data is processed in the United States.
• Hosting Infrastructure — Our application and database are hosted in the European Union. User data at rest remains within EU/EEA data centres.

We have data processing agreements in place with all third-party processors. Data transferred outside the EU/EEA is protected by appropriate safeguards including Standard Contractual Clauses (SCCs).

7. Data Location

Your personal data is stored and processed using Lovable Cloud, a managed cloud platform that provides our database, authentication, file storage, and backend services. Details of the specific data centre locations used by Lovable Cloud are available upon request by contacting us at the address listed in Section 9.

The data controller is established in Switzerland, which has been recognised by the European Commission as providing an adequate level of data protection (adequacy decision). This means personal data flows freely between Switzerland and the EU/EEA without the need for additional safeguards.

When data is processed by third-party AI services (see Section 6), it may be temporarily transferred to servers outside the EU/EEA under appropriate legal safeguards such as Standard Contractual Clauses (SCCs). Audio recordings and transcripts are processed in real-time and are not permanently stored by third-party processors.

8. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction.

9. Data Controller

The data controller responsible for your personal data is:

If you have questions about this Privacy Policy or wish to exercise your data protection rights, please contact us using the details above.

10. Governing Law

This Privacy Policy is governed by the laws of Switzerland and the Swiss Federal Act on Data Protection (FADP). For users in the European Economic Area, the General Data Protection Regulation (GDPR) also applies. For users in the United Kingdom, the UK GDPR applies.